March 26, 2020—While the policy and regulatory environment continues to adapt to the unprecedented challenge of COVID-19 and the focus at this time is appropriately on identification and treatment, in the coming months those in the healthcare industry will begin to consider the longer-term impacts of this pandemic. For Medicare Advantage (MA) organizations, one major question will be how COVID-19 will affect billions of dollars in Quality Bonus Payments (QBPs) tied to the Star Ratings program for 2021, 2022 and beyond. The following is a high-level overview of considerations; and of course, this may change as policy evolves. If you would like to keep updated on this topic or are interested in more-specific analyses and recommendations for your organization, please contact me at adam@zahealth.net.
First, it is important to review the timeline for the Star Ratings. 2021 Star Ratings will be the basis for 2022 Quality Bonus Payments. These will be publicly released this fall based on clinical quality metrics reflecting 2019 care and CAHPS and HOS surveys currently (or soon to be) in the field. Other administrative measures also will reflect events in either 2019 (e.g. complaints and appeals) or 2020 (e.g. call center measures).
CMS has a policy to make accommodations to Star Ratings in the event of Extreme and Uncontrollable Circumstances, but the regulation generally considers the ability to conduct surveys (CAHPS and HOS) and the HEDIS exemption is specifically for the prior calendar year (thus the 2022 Star Ratings). Additionally, while Emergency Declarations and Major Disaster Designations have been declared across the country, these have not, to date, included Individual Assistance areas. Thus, it is possible that even though there is a nation-wide FEMA disaster, some contracts will not qualify for the existing Extreme and Uncontrollable Circumstances exemption.
Thus, barring any additional accommodation from the administration, plans (and their provider partners whose compensation may be tied to Star Ratings) should be considering the following for 2021 Stars (2022 QBPs):
- Inability to do chart review for 2019 hybrid HEDIS measures (e.g. Comprehensive Diabetes Care measures) because of closed provider offices and burden treating COVID-19 patients
- Likely lower scores on the 2020 CAHPS survey because of more limited access to providers and care (note the 2020 Stars are increasing the value of experience measurers by 33%)
- Lower 2020 HOS scores especially on mental health-related metrics
- Effects on Improvement measures related to the changes in hybrid HEDIS, CAHPS and HOS measures
For 2022 Stars (2023 QBPs), plans should consider:
- Lower scores on HEDIS screening measures (e.g. Breast Cancer Screening) since many systems have moved away from doing these and it will be difficult to fill all gaps once screenings resume
- Possible increases in complaints, appeals and disenrollment related to care disruptions, staffing disruptions and strained access
- Lower scores on medication adherence measures since many individuals may not have been able to obtain their prescriptions through usual methods
- Fewer completed SNP care management assessments and lower scores on other SNP Care for Older Adult measures
- The validity of the readmission measure given the change in hospital usage for 2020
Furthermore, plans should also consider that changes in measure scores may not result in changes in measure-level Star Ratings, as cut points are set based on the current year’s distribution of results. Thus, areas that were affected less (e.g. some rural areas) could see a different overall result than those plans serving New York City or Detroit, which have been particularly hard-hit to date.
Finally, even if CMS moves forward with accommodations for MAOs as they have done for provider quality reporting, many provider contracts still incorporate Star Rating measure results into their payment policies. Thus, adjustments to these contracts may be needed to recognize this exceptional and unprecedented event.
*ZAHealth has the knowledge and experience to guide you through this changing landscape and ensure optimal positioning for your organization. Contact us today. “We start with the end in mind”