Introduction

CMS recently released the CY 2025 Advance Notice of Methodological Changes for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies Advance Notice. BHA would like to share a quick sumary from stars lens.

Net Payment Impact

Part C & D Star ratings - Proposed Changes

In the Advance Notice, CMS provided Star Ratings updates that include

• providing the list of eligible disasters for adjustment,
• non-substantive measure specification updates, and
• the list of measures included in the Part C and D Improvement measures and Categorical Adjustment Index for the 2025 Star Ratings

CMS stated that new measures and measures with substantive specification changes must be added or updated through rulemaking and must remain on the display page for at least two years prior to becoming a Star Ratings measure.

CMS uses the Advance Notice and Rate Announcement process to announce non-substantive specification changes and to remove measures.

Reminders for 2025 Star ratings

CMS is announcing a deadline of June 28, 2024, for all contracts to make their requests for review of the 2023 appeals and CTM measure data for the 2025 Star Ratings

Measure Updates for 2025 Star Ratings

CMS reminded Plans that starting with the 2024 measurement year (2026 Star Ratings), the weight of patients’ experience and complaints and access measures will be reduced to 2

Changes to Existing Star Ratings Measures for the 2025 Measurement Year and Beyond

Universal Foundation Measures

As discussed in the 2024 Rate Announcement, CMS will add Depression Screening and Follow-Up for Adolescents and Adults (Part C) and Adult Immunization Status (Part C) to the 2026 display page based on the 2024 measurement year.

Breast Cancer Screening

The current Breast Cancer Screening measure assesses screening for members aged 50-74. NCQA is considering revising it for the HEDIS MY 2024 Technical Update to include screening for members aged 40-74. Adding an age group is a substantive measure specification change; thus, the updated measure will be on the display page for two or more years and proposed through rulemaking prior to adding it. CMS intends to keep the legacy measure in the Star Ratings, while the new measure is on display

Diabetes Care - Eye Exam

Possible updates to the clinical codes by NCQA for MY 2025. It is a non-substantive since it updates the clinical codes with no change to the target population

Statin Therapy for Patients with Cardiovascular Disease

To accommodate those with a history of statin intolerance, NCQA plans to add an exclusion for MY 2025. This narrows the measure's population coverage and is a non-substantive update.

Plan Makes Timely Decisions about Appeals and Reviewing Appeals Decisions

Proposed changes include eliminating additional days for electronically submitted appeal files, aligning portal submission deadlines with existing regulations, and using the electronic system receipt date and time for electronic submissions, impacting both measures

CMS is considering eliminating the additional days the IRE allows for appeal files that are submitted electronically. Currently, the IRE includes additional days to make allowances for any mail delays. Because the IRE now receives over 99 percent of case files electronically via the portal, CMS is considering updating the language in the IRE Manual to use a deadline for timely portal (that is, electronic) submission that aligns with the timeliness requirements

These substantive changes would go through rulemaking, and legacy measures would remain until updated measures are on display for at least 2 years

Care Coordination

CMS is considering updating the Care Coordination measure by replacing two existing questions with alternative ones from the CAHPS survey. The potential six-item composite includes three questions about test results and three about other aspects of care coordination. CMS noted that changes to this measure would be a substantive update.

Part D Measures

Medication Adherence for Diabetes Medications | Medication Adherence for Hypertension (RAS Antagonists) | Medication Adherence for Cholesterol (Statins)/ Statin Use in Persons with Diabetes (SUPD) | Medication Therapy Management (MTM) Program Completion Rate for CMR

CMS proposes using Common Medicare Environment (CME) instead of Enrollment Database (EDB) for Part D Star Ratings measures to identify hospice and ESRD status beginning MY 2024

The proposed update is considered non-substantive as it involves changing the data source without impacting measure calculations.

Members Choosing to Leave the Plan

Two changes:

1. CMS plans to adjust the years of service area data used to identify beneficiaries leaving a contract due to a move out of the contract service area to better reflect contract service area at the time of the disenrollment. This change will more accurately identify members moving out of the contract service area
2. CMS also plans to ensure that when beneficiaries transition from misaligned to aligned/integrated D-SNPs, their enrollment status is treated as involuntary disenrollment, with exceptions for certain cases

These changes are non-substantive, aiming to enhance measure accuracy & narrows the population covered, implemented from 2026 Star ratings

Retirement of Star Ratings Measures

Care for Older Adults – Pain Assessment

NCQA is retiring this indicator, which is part of the Care for Older Adults measure set, starting MY 2025. The current measure, reported only for Special Needs Plans, will be replaced with a new measure that encompasses a broader population of Medicare Advantage members, addressing the deficiencies of the existing indicator.

CMS used the new rule which started with MY 2024 that would allow CMS to remove a Star Ratings measure, without separate rulemaking, when a measure steward such as NCQA retires a measure.

Potential New Measure Concepts and Methodological Enhancements for Future Years

Apart from the above measure updates, CMS is soliciting comments on multiple new measure concepts and methodological changes that could be implemented for future Star Ratings

This includes changes to or addition of following measures:

• Health Outcomes Survey
• Blood Pressure Control for Patients with Hypertension
• Breast Cancer Screening Follow-Up
• Social Connection Screening and Intervention
• Chronic Pain Assessment and Follow-Up
• Tobacco Use Screening and Cessation and Lung Cancer Screening and Follow-Up
• Functional Status Assessment Follow-Up
• Medicare Plan Finder Drug Pricing Measure (Part D)

Stay tuned to get insights on these new measure concepts!

Source:

1. CMS 2025 MA Advance Notice
2. Fact Sheet – 2025 MA Advance Notice