Advance Notice

CMS released the MA Advanced Notice yesterday. The biggest stars announcement is that HPC is being pushed back until 2022. CMS wants to include observation stays because than can also represent failure to prevent serious complications. The two Statin measures are sill on track for inclusion this year.

CMS is still planning on removing BAPP because they want to decouple audits and enforcement. They mentioned this possibility in last year’s call letter.

For the four appeals measures, CMS proposed to ease the penalty for failing data validation audits. Instead of knocking contracts down to 1 star, they proposed a scaled penalty system (some large insurers were hit hard with this in recent years). CMS devoted 8 pages of the Advanced Notice to outline their plan (page 114). CMS has also proposed a replacement for Part C timeliness in 2021.

CMS proposed several new display measures around opioids. We expect to eventually see something around opioids to work itself into Stars.

Two highly weighted HEDIS® measures are also undergoing revision. CMS is looking to replace the All-Cause Readmission measure in 2021, and they raised the possibility of an administrative compliance for controlling blood pressure.

Other Notes:

• New denominator exclusion for MTM

• Exclude VBID model participants from cut point calculations.

• Transition of care for 2022

• Follow up ER visits for 2022

• Variety of other measures under testing

• Tweaks to medication adherence around ESRD and inpatient stays