Despite the hectic pace of the fourth quarter, December is a stellar time to pause and reflect. As I reflect on the year, it’s been enthusing and gratifying to see health plan colleagues focus on true innovation, on adoption of high-impact emerging technologies tailor-made to Medicare Advantage and Star Ratings needs, and on the returned spirit of quality improvement within our work.
After connecting with health plans across the country this fall, I’ve noticed this annual reflective phase is filled with less excitement and more worry than normal. There is less confidence, and more trepidation about the challenges and unknowns ahead. More staff are stressed, confused and overwhelmed. There is less certainty about exactly what to do, when to do it, and perhaps most important, how to get started.
To help set you up for success, here are a few practical things to make sure are on your 2023 to do list.
Enhance Stars Reporting
The Medicare Advantage Star Ratings program is a data game. Many of the upcoming changes require extensive updates to reporting and analytics. Plans must know and action the right measures, intervene with the right members for the right reasons, and engage the right providers for the right reasons.
- Ensure your Stars reporting package computes the Improvement measures, accounts for Tukey impact on cutpoints, and calculates the Reward Factor.
- Until CMS confirms measurement year (MY) 2023 changes, model multiple regulatory scenarios and compute a proxy for the Health Equity Index to ensure all needed activities are impacting the member cohorts necessary for success across all measurement dimensions.
- Track Part C Summary and Part D Summary ratings in your contract dashboard to mitigate hidden Past Performance risks.
- Make sure member and provider reporting includes all measures. Use self-reported pulse data as gaps in care for the Consumer Assessment of Healthcare Providers and Services (CAHPS) and Health Outcomes Survey (HOS) measures, and display data for CAHPS and HOS measures alongside Healthcare Effectiveness Data and Information Set (HEDIS) and Prescription Drug Event (PDE) measures.
Create Health Equity Reporting
Earning a 4+ Star overall rating and earning the Health Equity Index will require our current math to evolve. Though CMS has not yet finalized the details for health equity accountability through Star Ratings, CMS has shared a potential structure for a Health Equity Index, and we already have access to data that outlines many current disparities.
Expand your Star Ratings reporting suite to:
- Mathematize disparities for dual status, low-income subsidy eligibility and disability status.
- Mathematize disparities by race, ethnicity and language (REL). If you do not have solid REL data yet, add data collection efforts to your 2023 workplan.
Emphasize Star Ratings Needs in 2024 Bid Planning
It is still rare for Star Ratings needs to be adequately considered during the bid development phase. Most bid design teams have no idea that the Tukey cutpoint rebasing in MY 2022 will change operating targets needed to earn the quality bonus payments they are striving for. Even fewer realize the bid and benefit changes needed to ensure Star Ratings success amidst the many known and proposed MY2023 and MY2024 Star Ratings program, measure and technical changes.
- Schedule time with your actuarial teams to talk through the needs.
- Assign an analyst to help structure return on investment analyses to demonstrate the medical expense and accretive Stars value of the benefit enhancements needed for success.
Develop an ECDS Conversion Strategy for Colorectal Cancer Screening
Most plans improve their final measure rates between 6-10% through the hybrid HEDIS measurement model which will be eliminated in 2024. It will be tempting to wait until this measure officially converts to the Electronic Clinical Data Systems (ECDS) measurement model in MY 2024 to implement a measure digitization workplan. But CMS gives a two-year notice period to prepare for substantive changes because they know we need to use those 24 months to ensure success. Maintaining strong performance will require time and effort that may not be feasible if you wait until 2024 to begin.
Here are some things to add to your 2023 workplan to ensure your MY2024 success:
- Develop a strategy to engage with members to capture self-reported data regarding their last completed screening.
- Establish process to collect ECDS-compliant numerator data or fetch the right chart for conversion to ECDS-compliant data set.
- Alert field teams, HEDIS interventionists, and vendors regarding measure transition to ECDS and adjust data transmission processes as needed.
- Work with your HEDIS auditor to convert all supplemental data sources for ECDS compliance, and optimize auditor-approved options for case management data sources.
Prepare for Changes to Flu Measures
The National Committee for Quality Assurance (NCQA) is transitioning flu measurement from CAHPS to HEDIS using the Adult Immunization Status (AIS) measure for MY 2023, but CMS has not finalized a decision or timing to convert the flu shot measure from CAHPS to HEDIS for Star Ratings. Given the commitment by CMS, NCQA and the National Quality Forum to digital quality measurement and alignment across programs, this change could be quickly made by CMS.
- Establish a clear risk tolerance for weathering a potential change in this measure.
- Action accordingly in your 2023 workplan.
Create a Star Ratings Roadmap
With the nature and extent of change ahead, it is simply no longer enough to create a short-term Stars workplan. Establish a clearly defined project plan with short, medium and long-term goals for the next one, three and five years which:
- Educates the entire organization in 2023 to ensure every employee understands CMS’ quality strategy, how they impact the current and future Star Ratings landscape and how to align routine operations and daily decisions for Stars success.
- Includes readiness assessments for each primary new need before identifying specific activities or investments to be made to ensure that effort and investments align with the root causes of your organizations gaps and needs.
- Deploys intense 2023 analytics to deeply understand REL, social risk factors, LIS, dual eligible and disabled members, and Special Needs Plan Single Contract impacts.
- Creates a detailed digital HEDIS and interoperability roadmap, capturing HEDIS, risk adjustment and provider interoperability requirements.
- Accounts for known and potential measure, program and industry changes.
- Accounts for emerging issues with indirect impact on member experiences and Star Ratings measures.
- Accounts for strategic investments and tactical activities with timelines, accountability and budgets.
Note for California Plans Operating D-SNPs
California regulators confirmed they will be de-consolidating Dual Eligible Special Needs Plan (D-SNP) members into separate H-contracts for MY2024. This means that all measures will follow the member into separated, de-consolidated contracts in MY2024. This requires immediate, intense effort quickly!
- Model member-level gap data for all measures for the SNP and non-SNP members to see how they performed in MY 2022. Include HEDIS, PDE, CAHPS and HOS.
- Engage the bid team to ensure each de-consolidated cohort has a customized bid that supports the Star needs.
- Expand MY 2023 Stars reporting to include modeling not only of the current contract structure, but also the de-consolidated contracts.
- Begin adjusting interventions, incentive programs, reporting and accountability in 2023 in preparation for the January 2024 de-consolidation impacts.
As you reflect on 2022, may you relish the joy of the year’s successes and imagine the possibilities awaiting us in 2023.
The only constant is change, and 2023 is shaping up to be a year full of high-impact change for which tweaks alone will be inadequate to ensure success. Healthmine’s consulting team has extensive experience supporting plans with these activities, and many more. If you need help, email melissa.smith@healthmine.com for more information.