This is an update to our previous post on April 2, 2019 (the original text of that post is below).

CMS has released the Announcement of Calendar Year (CY) 2020 Medicare Advantage Capitation Rates and Medicare Advantage and Part D Payment Policies and Final Call Letter updating Medicare for CY2020 and beyond, including Star Ratings changes. Below is a summary of the changes, highlights of changes to medication-related measure, and some other important notes MA and MAPD plans will want to consider. In short, most elements remained consistent with the Draft Call Letter (with deviations noted below).

Summary of CMS 2020 Star Ratings Changes

*Change from the Draft Call Letter

Adherence Measure Adjustments

  • ESRD exclusion
    • Now an exclusion for all three adherence measures plus SUPD.
    • Considering using Encounter data to identify it as well as CWF.
  • Hospice exclusion
    • Exclude beneficiaries who elected to receive hospice care at any time in the measurement year (instead of applying a PDC adjustment for hospice enrollment).
    • Would apply to 2020 Star Ratings (2018 measurement year).
  • IP and SNF stays for MAPD*
    • Currently PDC adjustments for SNF are PDP only. CMS will begin to use MA Encounter data in addition to CWF and expand to MAPD. Begins in 2019 measurement year (2021 Star Ratings).
    • Considering using encounter data for 2022 Star Ratings.


  • Not moving forward with the 3x weighted measure
  • Keeping it at 1x weight for 2020 and will consider changing it in the future.


  • Will be retired from the Display page and no longer included on the Patient Safety reports.

Medication-Related Measures

  • New medication-related Display Measures are being adopted and considered, including polypharmacy measures (more information below).

Adjustments for LIS/DE

  • CAI still in place to adjust overall Part D and Part C summary scores based on LIS/DE population.
  • Measures that are used to determine the CAI adjustment have changed.
    • Now includes all three adherence measures, SUPD, and SPC.
  • Additionally, PQA has reviewed their measures and provided draft recommendations for how to risk-adjust adherence measures. These are under NQF review and, if endorsed, CMS will consider how to adopt these adjustments (but likely not until the 2021 measurement year or later).

Cut Point Methodology

  • No changes to methodology for calculating Star Ratings at this time.
  • Will not be adopting changes outlined in the Proposed Rule in 2018.

Extreme and Uncontrollable Circumstances

  • Adopting the policy from the Proposed Rule.
  • Defined “affected contracts”: If a certain minimum percentage of beneficiaries (25%) reside in the FEMA-designated assistance area, would take the higher of the 2019 or 2020 measure score for select measures.


  • Should be ≥2 Rx claims on different dates of service.
  • Proposed for 2021 Star Ratings (using 2019 data).

Key Changes to Medication-Related Measures

New 2020 Display Measures

  • Transitions of care (Part C)
    • Percent of discharges who have an inpatient admission, discharge, patient engagement, and medication reconciliation within 30 days during the measurement year.
  • Follow-up after Emergency Department (ED) visit for patient with multiple chronic conditions (Part C)
    • Percent of ED visits who have high-risk multiple chronic conditions who had a follow-up service (can be a telephone visit or case management services) within 7 days of the ED visit.

New 2021 Display Measures (will be considered for 2023 Star Ratings)

  • Concurrent Use of Opioids and Benzodiazepines (COB)
  • Polypharmacy Use of Multiple Anticholinergic (ACH) Medications in Older Adults (Poly-ACH)
  • Polypharmacy Use of Multiple Central Nervous System (CNS)-Active Medications in Older Adults (Poly-CNS)

Potential Future Measure Concepts

  • Adherence to Antipsychotic Medications for Individuals with Schizophrenia (Part C)
    • HEDIS 2020 measure
  • Diabetes Overtreatment (Part C)
    • This would assess whether members are being over-treated by trying to achieve too aggressive an A1c goal (as defined by A1c level and medications)
    • HEDIS 2021 measure
  • Antibiotic Utilization Measures (Part C)
    • This would measure antibiotic prescribing practices related to three of the most common acute respiratory conditions for which inappropriate prescribing of antibiotics occurs frequently in the ambulatory care setting.
    • HEDIS 2020, if approved

Other CMS Call Letter Changes for MA Plans

Temporary Removal of Measure from 2020 Star Ratings

  • Controlling High Blood Pressure (Part C)
    • Revising due to new blood pressure guidelines.
    • Will change encounter definition, allow for telehealth services, and remove monitoring device readings.
    • Proposed Display Measure for 2020 and 2021, back to Star Ratings for 2022

Other Star Ratings Updates

  • Members Choosing to Leave the Plan (Part C and D)
    • New exclusion for move-outs.
  • MTM CMR Completion Rate (Part D)
    • Will update denominator to include members that received CMR that were in program less than 60 days.
  • Plan All-Cause Readmissions (Part C)
    • Display for 2021 and 2022, return for 2023 Star Ratings.
  • Adult BMI Assessment (Part C)
    • Removed for 2022 Star Ratings.
  • Appeals Auto-Forward (Part D), Appeals Upheld (Part D)
    • Removed for 2022 Star Ratings.

Retired Display Measures

  • Transition Monitoring Program Analysis (TMPA) and Formulary Administration Analysis (FAA) (Part D)
  • Diabetes Medication Dosing (DMD) (Part D)
  • High Risk Medication (HRM) (Part D)

Some Changes to Existing 2020 Display Measures

  • Use of Opioids at High Dosage and from Multiple Providers (OHDMP) and Antipsychotic Use in Persons with Dementia (APD)
    • Update the methodology to calculate total days’ supply:
      • Any day’s supply that extends beyond the end of the measurement period will be excluded.
      • In the case of multiple Rx claims with the same date of service, total days’ supply will only include the supply of the claim with the longest day’s supply.
      • In the case of multiple overlapping claims with different dates of services, there will be no adjustments for early fills or overlapping days’ supply.
  • MPF Price Accuracy
    • Updated to better measure the reliability of a contract’s MPF prices.
    • Display for 2020, considered for the 2022 Star Ratings.
  • Other impacted display measures:
    • Problems Getting Information and Help from the Plan and Problems with Prescription Drug Benefits and Coverage Disenrollment Reasons Survey composite measures (Part D)
    • Care for Older Adults – Functional Status Assessment Indicator (Part C)
    • Hospitalization for Potentially Preventable Complications (Part C)

Other Updates

  • Osteoporosis measures being reviewed based on new guidelines:
    • Osteoporosis Testing in Older Women (Display Measure)
    • Osteoporosis Management in Women Who Had a Fracture (Star measure)

Potential New Measure Concepts

  • Pain Management (Part C)
    • NCQA assessing use of non-opioid therapies for pain
  • Patient-Reported Outcome Measures (Part C)
    • CMS is considering using new and more targeted PRO measures to hold contracts accountable for the outcomes of care for their members. “We are interested in obtaining feedback and suggestions on PRO measures, including targeted PRO measures and more general ones such as the existing HOS outcome measures.”
  • Interoperability Measures (Part C)
    • CMS is seeking comment on ways to measure health plans’ progress in maximizing their capabilities to exchange health information with other plans, health care providers, and others and to provide beneficiaries access to their health data.
  • Physician/Plan Interactions (Part C and D)
  • Cross-Cutting Topic – Exclusions for Advanced Illness (Part C)
  • Cross-Cutting Topic – Measure Digitalization (Part C)

Our original post from April 2, 2019, regarding the 2020 Star Ratings draft changes from CMS:

At the end of January 2019, CMS released notice of impending changes to the methodology of Medicare Advantage (MA) “Capitation Rates and Part D Payment Policies.” This comes as the second of a two-part announcement from CMS, both in the interest of driving quality up and costs down by encouraging innovative and creative competition among plans. (See part one here and part two here.)

These changes haven’t been finalized as of yet (April 1, 2019), but don’t expect to see too much variation when the final call letter is announced.

Check back here for updates as these changes unfold.

Key CMS Changes to 2020 Methodologies

Although the complete list is quite extensive, there are a few primary changes that MA Part D (MAPD) plans will want to know about. Here’s the summary, and we’ve added some notes for places RxAnte can help if you need it:

  • “High-risk medications (HRM)” is being retired from the Display page. Although not counted in Star Ratings, display measures do facilitate internal quality improvement efforts for MAPD plans, making this change particularly important.
  • “Statins use in persons with diabetes (SUPD)” will now be triple-weighted (3x-weighted). For 2020 Star Ratings (related to 2018 data), this can cause some undo administrative and measurement burdens for plans.
  • Plans will be given considerations for the impact of “extreme and uncontrollable circumstances” (such as hurricanes or wildfires). As these types of events have been quite prevalent and increasingly detrimental over the last decade, this change is instrumental to ensuring fairness to plans whose providers and members are effected.
  • New exclusions are being considered for end-stage renal disease (ESRD), hospice, and inpatient/skilled nursing facility (SNF) stays. Under these proposed changes, plans will no longer be penalized for members in hospice, with ESRD, etc., who are not adhering to their medications.

CMS and New Medication-Related Measures

Among the rash of changes, CMS is considering a number of new medication-related measures as well, including: 

  • Adherence to Antipsychotic Medications for Individuals with Schizophrenia (Part C)
  • Concurrent User of Opioids and Benzodiazepines (COB)
  • Polypharmacy User of Multiple Anticholinergic (ACH)
  • Medication in Older Adults (Poly-ACH)
  • Polypharmacy User of Multiple Central Nervous System (CNS)-Active Medications in Older Adults (Poly-CNS)

Note: These are all measures RxAnte can and does help with. We have the technology to view and target these individuals for interventions that actually improve adherence. We have also done research on medication use and adherence, specifically with some of these medications, so we are well prepared to help MAPD plans maximize the value of medication use measures by achieving higher Star Ratings.

What is the Future of MAPD Star Ratings?

This isn’t the first time CMS has made changes to these programs and it certainly won’t be the last. If history is any gauge, however, CMS will continue to measure and refine quality measure ratings for health plans (and others) in an effort to improve costs and care. Although everyone won’t agree with the tactics or even the strategies, it’s certainly a mission the entire healthcare community can get behind.

The future of Star Ratings is still in the works, and the 2020 Star Ratings year is actively evolving. Keep an eye on our blog for updates, our stance, and education about how these changes impact MAPD plans.