Featured Health Business Daily Story, Oct. 3, 2012
Reprinted from MEDICARE ADVANTAGE NEWS, biweekly news and business strategies about Medicare Advantage plans, product design, marketing, enrollment, market expansions, CMS audits, and countless federal initiatives in MA and Medicaid managed care.
CMS is considering whether more of its star-rating quality measures for Medicare Advantage and Part D plans should be based on results at the plan or parent-company level rather than at the contract level, as is usually the case now, the agency’s overseer of star-rating measures told a conference session Sept. 5.
Elizabeth Goldstein, Ph.D., director of CMS’s Division of Consumer Assessment and Plan Performance, said that the agency would like feedback from plans and others on “what is the appropriate unit of analysis for quality measures.” Speaking at CMS’s fall MA and Part D conference in Hunt Valley, Md., Goldstein explained that perhaps, for instance, call-center performance measures might be “more appropriate” in the future to assess at the plan rather than the contract level.
Similarly, she continued, maybe some clinical measures should be assessed at the parent-company rather than a lower level. Goldstein asked for comments on that idea as well.
She got some instant feedback in the question period from Jane Galvin, director of regulatory affairs at the Blue Cross and Blue Shield Association. Galvin noted that medical loss ratios, on which MA plans will be measured and subject to sanctions beginning in 2014 (see story above), now are based on the state level for commercial plans. Should this be changed for MA plans, which often are part of the same parent organizations, it could be something the insurers would be “concerned” about, she said.
Cynthia Tudor, Ph.D., director of CMS’s Medicare Drug Benefit and C&D Data Group and another speaker at the session, said Galvin’s comments were “interesting” but added that there is a “whole group” of health plans pushing for having star-rating categories measured at a higher level in an insurance company’s operations.
Agency officials also solicited feedback on the plan improvement star-rating measure CMS will use for the first time in 2013. While the form of the rating is set for 2013, Vicki Oates, director of CMS’s Division of Clinical and Operational Performance, said that the agency will request comments for use in the 2014 measure on whether it should be utilized as an absolute level or instead as an overall adjustment to a plan’s summary stars score.
The improvement measure, as it stands now, is just a single-category star rating to reflect whether an MA plan improved in its summary score from one year to the next, Goldstein pointed out. And Oates, in response to a question from MAN, noted that CMS in effect holds high-performing plans “harmless” in this measure since they don’t have much room for improvement in their scores.
Although MA plans queried by MAN generally seem appreciative of CMS’s inclusion of an improvement measure as a way for plans to show their value gains and comparisons with fee-for-service Medicare, one of them said that the new measure is just “one of 52” scored for the star ratings and therefore is not getting enough weight. Conversely, an audience member at the stars session said plans going from three to four stars should not get the same “reward” as a plan remaining at a higher rating, contending that star scores should be “absolute” and not related to “momentum.”
Tudor responded that “we’re getting lobbied by improvers” for recognition of their gains, and said it’s hard to believe that inclusion of this one improvement measure will confuse beneficiaries.
She also said that CMS expects to continue the transparency move it began last December (MAN 1/5/12, p. 1) of sending a memo to plans outlining the star-rating changes being contemplated for the following year. Moreover, there now is an appeals process that gives plans “multiple opportunities” to contest their star scores, Tudor added.
But CMS does not seem to be wavering from its premise that both MA and Part D plans should be “accountable” for the care furnished by their network providers, as Goldstein put it.
The agency, according to Oates, also is looking at individual star-rating measures for their potential to be subject to “gaming.” She cited as an example the measure regarding timely decisions on appeals for prescription drug coverage. If it finds “outliers,” presumably plans that process appeals quickly only at times they’re being measured, she said CMS might request “case-file information” and check on overall patterns in such areas as written notifications to beneficiaries and timely submission to independent review entities. Data found to be inaccurate or incomplete may result in reducing the rating for the specific measures involved to one star, Oates added.
The 2013 MA and Part D star ratings go live on CMS’s website Oct. 11, and Timothy Love, deputy director of the CMS Center for Medicare, said at another session of the conference that “we’re likely to have additional five-star plans” for next year. This could have a big impact on the MA market since, CMS Center for Medicare Director Jonathan Blum said at another conference this month, about 12,000 beneficiaries so far have signed up for five-star plans outside of the fall Annual Election Period since last December, when the agency began allowing year-round marketing and enrollment for five-star plans.
The message from Blum was much bleaker for low-rated plans. Speaking at a session of the America’s Health Insurance Plans annual Medicare conference in Washington, D.C., Sept. 11, he said CMS is taking new steps to make it “very difficult” for Medicare beneficiaries to stay in plans with a history of consecutive ratings of less than three stars this coming year. He said enrollees in such plans for 2013 will get letters from CMS asking if they are sure they want to be members of such plans. And CMS is “turning off” the automatic mechanism to sign up for those low-rated plans from the Medicare website, meaning that would-be members will have to contact the plans directly to enroll.
© 2012 by Atlantic Information Services, Inc. All Rights Reserved.
CMS Star Quality Ratings: Shifting Strategies for Medicare Advantage and Part D Plans and Providers, from the editors of Medicare Advantage News, provides an in-depth look at the impact and implications of CMS’s star-ratings system so far, as well as how the star-rating program is likely to change in the future. Learn more at the AIS Marketplace.
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