CMS’ Proposed Rule: What You Need to Know


The Centers for Medicare & Medicaid Services (CMS) issued a slew of high-impact proposals impacting Medicare Advantage (MA) and Star Ratings. The following noteworthy changes are recommended:

  • Returning member experience measures. Consumer Assessment of Healthcare Providers and Systems (CAHPS) and administrative measures may be weighted 2x in measurement year (MY) 2024.
  • Adding five new Healthcare Effectiveness Data and Information Set (HEDIS) and Part D measures in MY 2024, in addition to the already-codified return of the 3x-weighted Health Outcomes Survey (HOS) measures.
  • Replacing Reward Factor with Health Equity Index in MY 2025.
  • Risk-adjusting the medication adherence measures in MY 2026.

Though these are the most noteworthy, there are many other impactful Star Ratings and operational proposals. These changes will be a seismic shift requiring significant and rapid changes in Star Ratings programs which warrant action now, even while we await the Final Rule.

Here are five things to do during the holiday slowdown.

1. Communicate Updates to Your Benefit Design Team

2024 bids must include enough of the right benefits, tools, services and supports to support CMS’ Star Ratings proposals. The many non-Stars proposals released by CMS this week may prevent benefit design teams from realizing the bid-related needs for MY 2024 success. Send them a summary of the 2024 Star Ratings-related needs along with a draft of your action plans from step three below so they can confirm the bid includes funding for all programs you propose launching in 2024 at a utilization level you’ll need for Stars success.

2. Expand Reporting and Analytics

Since its inception, Stars has been a data game. The odd measure and technical stability in the program in recent years lulled many into thinking that basic reporting and basic analytics would be enough to earn industry-leading success. Those days are officially over. Begin analyzing contract, member and provider performance on each of the new measures proposed. Create your math labyrinth across all of the proposed health equity elements, including proposed new measures and sensitive to looming D-SNP Single Contract de-consolidation.

3. Develop Action Plans for Technical Changes and Emerging Issues

Each proposed change, proposed new measure and emerging industry issue warrants a unique, detailed 2023 action plan. Create a detailed action plan for each issue and topic. Socialize rapidly with leadership so they can be launched as soon as we know which changes are finalized for 2024 success.

4. Return Star Ratings to a Teaching and Silo-Busting Function

Stars is not a “thing.” It’s the result of high performance hardwired throughout the organization. The best Stars workplans are filled with teaching, collaboration, supporting and leading change. There is so much to teach in MA and Star Ratings right now. Some will be about Stars technicalities and new measure technical details.  But much more will be about the deep, complex, interrelated topics, process changes and needs underneath the content that we need every colleague in every department to align their work with. Make sure your Stars team has a strong enough voice and role in your organization to teach with confidence and lead the organization through this phase of change. Make sure your Star Ratings leader has a direct voice to leadership. They’ll need clear line of sight to influence or make decisions and access funding, presents data and performance directly to leadership, and be empowered to urge others to act and course correct when performance is off-track, not moving fast enough or out of alignment with the precision and urgency of action plans.

5. Execution and Precision Are the Keys to Success

Far too frequently, plans launch programs, strategies and initiatives that are directionally aligned with Star needs but stop short of tackling the last mile.  The last mile of the measure technicalities, the last mile to help providers drive success, or the last mile to get the right members taking the right action at the right time. While we must appreciate and celebrate good faith efforts, this is not the time to reward and applaud participation alone: it’s the time to reward and applaud successfully achieving goals and outcomes. Make sure every project and process tackles the last mile. Be relentless in the pursuit of excellence.

Please take the time to provide feedback to CMS on the full text of the proposals.

Healthmine’s consulting team has extensive experience supporting plans with these activities, and many more. If you need help, email

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