Each year as Q4 approaches, Medicare Advantage Part D (MAPD) health plans await the release of updated cut points for the approaching Star Year to understand how these changes will impact their Star Ratings. CMS recently released the new 2022 Star Rating cut points, and RxAnte’s client analytics team will be hard at work providing an updated in-depth industry analysis to account for the impact of these changes on MAPD plans’ Star Rating performance.
As we await this year’s Star Ratings and industry analysis, we’ve asked Tori Erxleben Rush, PharmD, Director of Clinical Pharmacy Programs at RxAnte, for her input and expertise to better understand how these newly released 2022 cut points may impact health plans’ ratings.
Based on the preview received for the CMS 2022 technical notes, what are the biggest changes that MAPD plans must be aware of?
Despite the unforeseen circumstances of the COVID-19 pandemic, we’ve seen strong performance in medication adherence across the board for our clients in 2020; as a result, we expected the Center for Medicaid and Medicare Services (CMS) to raise the cut points. While we typically advise our clients that small increases are expected to occur to some extent each year, we were still surprised to see such drastic increases for 2022—the most notable being the three percent increase for 5-Star cut points for two adherence therapy measures.
Can you summarize what RxAnte is seeing as a result of the preview in terms of adherence and statin quality measures?
We’re still awaiting the release of the Star Ratings based on these modifications, but the CMS technical notes did give us insight into the different adherence and statin measures changes. The most significant change within the triple-weighted adherence measures occurred for diabetes, which saw a very substantial cut point increase of three to five percent across MAPD Star Ratings. For RASA adherence measures, cut points decreased anywhere from two to six percent, and statin adherence measures experienced moderate increases of one to three percent. Within the additional statin quality measures, we saw small fluctuations for Statin Use in Persons with Diabetes (SUPD) of around one percent and moderate changes of one to two percent for Statin Therapy for Patients with Cardiovascular Disease (SPC) measures.
We’ve also seen that the industry as a whole has made multiple changes to ensure that MAPD members were able to easily access their medications in order to properly manage their chronic conditions, despite the unforeseen circumstances this year. Many adaptations were made to health plans’ policies to make it easier, safer, and more convenient for patients to get the necessary prescriptions and care they needed. These changes included updating previous refill requirements, enabling and promoting telehealth visits, and offering medication delivery options; as a result, we saw that many of these actions contributed to improved performance among the triple-weighted adherence measures within our own book of business.
Are there other anticipated changes for 2022 and 2023 that MAPD plans should be aware of in terms of impacting performance? If so, what can they do to address these changes?
Other newly released information includes important details around proposed rule-making and anticipated changes from CMS moving forward: CMS is adding the “Tukey outer fence outlier deletion” method, which aims to remove outlier measure scores when calculating cut point thresholds. CMS has also opted to delay the implementation of “Guardrails” for cut points which would help limit the amount of variability that occurs among cut points each year. Both of these changes could contribute to a more challenging environment for MAPD plans because they make it more difficult to achieve a larger year-over-year improvement; as a result, it’s critical for plans to implement a strong pharmacy quality program that runs year-round and is able to adapt to changes as they arise in the industry.
Another element for plans to be aware of is around the COVID-19 relief program for 2022 Star Ratings: this relief allows health plans to use the highest Star Ratings for either the current or previous Star Rating year for multiple measures. This update may result in inflated Star Ratings for many plans, even if they actually experienced lower performance in calendar year 2020. Calendar year 2021 performance will likely be impacted as a result when this COVID relief program eventually ends.
Lastly, measure weighting is another significant consideration. This is the last year that patient access and experience measures are being weighted 2x, as they will increase to 4x weighted for the 2023 Star Ratings. This will have a large impact on how Star Ratings will be calculated. This update also means that health plans need to focus more on patient interactions and satisfaction in order to receive a high rating in this category; to address this, there should be a heavy emphasis improving continuity of care across different departments this upcoming year.
What can health plans do at this point of the year in order to combat these large cut point changes that are seen?
It’s critical to ensure that health plans have a strong medication adherence strategy in place since this is the time of year that members begin to qualify as either adherent or non-adherent. It’s important to consider that it’s never too late in the year to make program tweaks, revise adherence strategies, and adjust resources to improve adherence rates. While pharmacy quality should always be top-of-mind throughout the year, rising cut points, stricter thresholds, and fading COVID relief mean that it is crucial to ensure member targeting is optimized to reach members that can still achieve the targeted 80 percent proportion of days covered (PDC) rate since this can have a large impact on overall Star Rating scores.
While 2020 was an unprecedented time in the health care industry, this year will be more challenging for health plans plans’ medication adherence programs and their ability to achieve strong Star Ratings performance. Plans can combat these difficulties by including tactics to help members refill and obtain their prescriptions on time, visit their doctors regularly, and remain adherent to a safe and effective medication regimen.
RxAnte is always here to help provide guidance, expertise, and recommendations to existing pharmacy quality programs, regardless of the time of year. Contact us today to learn how we can evaluate your unique population mix at no cost and adjust your strategy to improve your health plan’s Star Ratings.