As promised, the Centers for Medicare & Medicaid Services (CMS) released stratified results for Star Ratings measures in an effort to encourage Medicare Advantage (MA) plans to address potential health disparities for enrollees with social risk factors (SRF). The Disparities in Health Care in Medicare Advantage by Race, Ethnicity, and Sex report outlines contract level scores for a subset of 2022 Star Ratings measures stratified by Low-Income Subsidy (LIS/DE) versus non-LIS/DE and disabled versus non-disabled. By sharing this stratified data set, CMS is focusing on creating incentives to reduce existing disparities related to LIS/DE and disability status—both within contracts and between them.
Addressing Within-Contract Disparities
Through this data, CMS has provided MA plans with the ability to identify within-contract differences in performance between subgroups for Star measures. Health plans can quickly identify potential disparities by comparing the differences in measure performance for members identified with a SRF (e.g., members with a disability) versus those members who do not have that SRF. Health plans may choose to prioritize specific measures for health equity initiatives based on the level of disparity identified from these measure level differences.
CMS would like to make any performance gaps between stratified groups within individual MA contracts publicly reportable. In the CMS 2023 Final Rate Announcement, the regulatory body proposed including this stratified reporting as part of the display measures on CMS’s Part C and D Star Ratings webpage and on the Medicare.gov Plan Finder tool in the future to help make the data accessible to beneficiaries in their reviews and selections of plans.
CMS is also expected to provide additional variables for stratification in future reporting.
Addressing Between-Contracts Disparities and the Proposed Health Equity Index
National performance scores are provided for comparison in the stratified data tables. This includes designations for measure rates by SRF (such as Disability Group) that are Similar, Higher, or Lower than national performance.
This data looks to be a clear precursor to the development of a new Health Equity Index that would focus on between-contract differences in performance for groups with Social Risk Factors, which was proposed in the 2023 MA and Part D Advanced Notice.
As a significant methodological change to Star Ratings, CMS is developing a single score Health Equity Index (HEI) to potentially replace the current reward factor as an incentive for health plans to address health care disparities for at-risk beneficiaries. CMS has also posited to include disability and LIS/DE data in a Health Equity Index. CMS is still considering what other data are available and what other SRFs might be appropriate to include over time.
Although the methodology is still in development by CMS, this new index will likely compare a contract’s performance on each measure by each SRF to national performance. For each Measure/SRF combination, the top third performing contracts will receive 1 point, the middle third of contracts will receive 0 points, and the bottom third of contracts will receive -1 point.
CMS proposed that the index will be calculated as the (weighted) sum of the above-described points divided by the (weighted) sum of the number of eligible measures. The Index will take into account the current weighting values of each Star measure.
Incorporating Health Equity Performance into Star Rating Work Plans
CMS has provided this data so that it may be used by contracts to inform and target their quality improvement efforts. We encourage you to also incorporate this into your Star strategies and program enhancements to prioritize new investments in the reduction of health care disparities.
First examine your performance within your own contract(s) by calculating the differences between your SRF Group (e.g., LIS/DE members) vs non-SRF Group measure performance. Prioritize those areas with the largest disparities.
Next, examine these same measures by SRF based on how your contract(s) compares to national performance. Prioritize Health Equity projects based on measures that rate a ‘lower’ status in combination of both LIS/DE and Disability scoring.
This is the beginning of a much larger emphasis on health equity performance—more updates to come soon when CMS next provides the stratified CAHPS measure data.
Every member of our team has weathered seasons of significant change, and established strategies for 4+ star success even during the most tumultuous periods of industry change. If you need help, please contact me at Dwight.Pattison@Healthmine.com for more information.
Dwight Pattison has over twenty years of healthcare industry experience focused on quality management, performance improvement, data analytics, and reporting. Fueled by a strong background in Medicare and Medicaid reporting and regulatory compliance, Dwight has directly led MCOs in achieving significant performance improvement results across numerous markets and product lines.
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