Key Points from the CMS Memo about 2015-2016 Star Ratings
CMS released details about enhancements to the Star
Ratings in 2015 and beyond. CMS has provided advanced notice of these
proposed changes ahead of the draft 2015 Call Letter in order to provide time
to receive and review comments. Comments must be submitted by Thursday, December 19th.
New 2015 Measures
CMS intends to add the following to
the 2015 Star Ratings. Each will be assigned a weight of ‘1’ since they
will be first year measures.
Part C
- Pharmacotherapy Management of COPD Exacerbation
- Initiation and Engagement of Alcohol and Other Drug
Dependence Treatment
- Special Needs Plan (SNP) Care Management
- Completion of annual health risk assessments
Part D
- Medication Therapy Management Program Completion Rate
for Comprehensive Medication Reviews
Changes
to Measures for 2015
CMS is modifying the methodology for
the following measures.
Part C
- Breast Cancer Screening – Change to impact 2016 Star
Ratings. Display measure for 2015 Star Ratings.
- Modification reflects changes in HEDIS 2014
- Annual Flu Vaccine – Change to impact 2015 Star
Ratings
- The flu shot question in CAHPS will be changed to ask
members if they have received a flu shot since July of each year instead
of September.
- The pre-determined 4 star threshold will be eliminated
for the 2015 Star Ratings due to the change.
Part D
- High Risk Medication – Change to impact 2015
Star Ratings
- This measure will use the updated PQA HRM list
- Medication Adherence for Diabetes Medication – Change
to impact 2015 Star Ratings
- CMS is adding two additional drug classes
- Appeals Upheld – Change to impact 2015 Star
Ratings
- Change from 6-month to 12-month measurement period.
- The pre-determined 4 star threshold will be eliminated
for the 2015 Star Ratings due to the change.
- Medicare Plan Finder Accuracy – Change to impact 2015
Star Ratings
- CMS proposes to include PDE claims from retail
pharmacies that are also reported by sponsors as being long term care,
mail order, or home infusion pharmacies.
- CMS will also remove the restriction to evaluate only
claims for 30-day supplies, and will evaluate claims for 30, 60, and
90-day supplies.
- Beneficiary Access and Performance Problems (Part C
& D) – Change to impact 2015 Star Ratings
- Change to the audit score calculation.
- Medication Adherence Measures – Change to impact 2015
Star Ratings
- The three medication adherence measures will be
adjusted to account for members with hospice enrollment or Skilled
Nursing Facility (SNF) stays. The Part D sponsor would not be responsible
for providing prescription refills for these medications.
- Only standalone PDPs have SNF data available for the
adjustment. All plans offering Part D will have hospice information
available.
- Obsolete National Drug Codes (NDCs) – Change to impact 2015
Star Ratings
- CMS will implement the PQA’s specification change to
account for obsolete NDCs.
Retirement
of Measures
- CMS plans to remove the Glaucoma Testing measure for
the 2015 Star Ratings.
Contracts
with Low Enrollment
- Contracts with 500 or more enrollees as of July 2013
will be included in the 2015 Star Ratings. These contracts in most cases
will have sufficient data to produce both overall and Part C and D
ratings. The HEDIS data for contracts with less than 500 enrollees will
continue to be posted on the display page.
Data
Integrity
- CMS will continue to take steps necessary to protect
the integrity of the data. CMS’ audits and other investigations have
consistently shown that sponsors fail to follow requirements for
forwarding Part C denials and auto-forwarding untimely Part D initial
coverage determination or redetermination requests to the IRE. Other areas
of concern are the two new proposed measures that focus on SNP care
management and MTM CMRs which are also based on organization/sponsor
reported data. If erroneous or biased data has been submitted, it is
CMS’s policy to reduce the measure rating to 1.
Changes
to Display Measures
- Measures that may be added to 2015 display page
and then to the 2016 Star Ratings:
- CAHPS measures about contact from a doctor’s office,
health plan, pharmacy, or prescription drug plan
- CAHPS – Complaint Resolution
- CAHPS – Health Information Technology – EHR measures
- Transition monitoring
- Combined MPF Price Accuracy
- Disenrollment Reasons
- There may be a change to the measure specification of
the Drug-Drug Interactions Measure.
Forecasting
to 2016 and Beyond
- CMS may remove the pre-determined 4 star thresholds
beginning with the 2016 star ratings.
- CMS is concerned that using whole-star individual
measures and pre-determined 4 star thresholds results in a loss of
information when aggregating to the levels of overall and summary
ratings.
- There will be no changes to the 4 star thresholds for
the 2015 Star Ratings.
- CMS will provide contract-specific information on the
impact of removing the 4 star thresholds prior to the comment period for
the 2015 draft Call Letter.
- Expected changes to measure specifications or
calculations based on possible NCQA revisions to HEDIS 2015.
- Osteoporosis Management in Women who had a Fracture
- Treatment with estrogen may
be removed, an upper age limit may be added, and dementia may be excluded.
- Monitoring Physical Activity
- The HOS questions may be
revised to include an outcome indicator that assesses whether patients
increased their level of physical activity.
- Plan All-Cause Readmissions
- Two changes possible: 1)
excluding planned readmissions 2) removing current exclusion from the
denominator for hospitalizations with a discharge date in the 30 days
prior to the Index Admission Date.
- Improving Bladder Control
- HOS questions will be revised
for the 2015 data collection. As such, data will not be available
for this measure for the 2016 and 2017 Star Ratings.
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