Cut Point Chaos, COVID Relief & QBP Risks Emerge in Plan Preview 2


In a rare midweek surprise, CMS released the Second Plan Preview of 2022 Medicare Advantage (MA) Star Ratings late on Tuesday.

Consistent with annual tradition, this kicks off a wave of celebration inside plans that earned 4+ Stars and a wave of panic as plans under 4 Stars now face the daunting task of shoring up their 4th quarter push strategies and work plans to earn the ever-elusive 4th Star.

With these details in hand, Healthmine has identified 3 important takeaways for Plan Preview 2:

Cut point chaos continues to reign supreme in MA

COVID did not relax MA plans’ focus on Stars. Approximately half of all cut points got harder to hit this year and only one-third of all cut points became easier to accomplish. Unsurprisingly, substantially all plans struggled with preventive care services, which caused cut points on these measures to decline. But plans got serious and focused throughout the pandemic on medication access, clinical care for chronic conditions, and optimizing experiences for their members, all of which drive cut point increases across most chronic condition management and member experience measures.


2022 Star Ratings results are misleading due to CMS’ COVID relief

The COVID relief in the 2022 ratings allows mature plans to use the better of current or prior year’s ratings for many measures. This gift manifests through strong 2022 ratings that many plan leaders know are simply not reflective of their current performance status. We’ve heard from many colleagues who are alarmed that this is preventing them from getting the staff, budgetary, and leadership support needed this fall to adapt to the MY2021 increased weighting of CAHPS and administrative measures to 4x, the new MY2022 measures (on which success will be difficult during the first year without meaningful investments), and to the increased competition from newer and often more nimble plans who are aggressively on the chase to earn their own 4+ Star Rating.

Medicare Advantage QBPs are in the crosshairs

While the Kaiser Family Foundation reports that the cost-per-beneficiary in MA is $321 higher than in Original Medicare, the Medicare Trustees simultaneously predict the Medicare Hospital Inpatient Trust Fund will run out by 2026 if no action is taken. Combined with projections that continued increases in quality bonus payments arising from increasing ratings (which are artificially inflated due to the COVID relief this year) and continued growth in MA enrollment, it is undeniable that the current MA payment construct is simply unsustainable financially. Combine this with the record profits recorded in 2020 by MA plans when utilization dropped due to the pandemic, and all signs indicate that both MA payments in general and QBPs are in CMS’ crosshairs. While substantially all stakeholders—from MedPAC to the Trustees and every credible industry voice—are offering ideas and proposals to solve this funding problem, CMS has plenty of easy, near-term ways to reduce QBPs by adjusting and evolving Stars performance without new regulation.

And here’s a bonus tip!

The latest Star Ratings Technical Notes contain a new label for each measure called the “Meaningful Measure Area.” As the Biden Administration and Administrator Brooks-LaSure look to make their mark on MA and Star Ratings, we know more change is imminent. In addition to the predictable measurement categories of Preventive Care, Chronic Condition Management, Patient Experience, and Medication Management, CMS has given us hints into the next generation of MA Star measure areas: Preventable Healthcare Harm, Transfer of Health Information and Interoperability, and Appropriate Use of Healthcare. For those of us long-timers in MA Star Ratings, adding this label to the Technical Notes and spotlighting these new measurement areas is a sure sign of more change to come!

What’s next?

Change is challenging—and there is plenty more change on the horizon. If you need assistance, Healthmine can help. From evaluating 4th quarter work plans to identifying 2022 opportunities, or simply providing staff augmentation support, our experts have deep Medicare Advantage and Star Ratings expertise to support your success.

For more information, email me at