The 2020 CMS Star Ratings for Medicare Advantage (MA) plans have been out since October. You know how you did. You know how your competitors did. But with the new year just weeks away, what can you do to ensure your team is ready to tackle the next quality reporting season – and maintain or improve your Star Rating?
From a beneficiary, payment and compliance standpoint, CMS Star Ratings performance continues to increase in importance. As competition stiffens among plans with 4 or more Stars, beneficiaries are increasingly comparing plan options, making your Star Rating more relevant than ever. Moreover, highly rated plans are awarded Quality Bonus Payments (QBPs) and higher rebates, while those failing to perform are penalized or terminated for consistently low ratings. Achieving higher CMS Star Ratings is not a “nice to have” – it’s a necessity, and insights into Star Ratings, including overall plan performance, measure-level performance, measure cut point movement, and Categorical Adjustment Index (CAI) impact provide a better understanding of the 2020 CMS Star Ratings and how you can improve your quality performance.
Understanding the 2020 CMS Star Ratings for Medicare Advantage Plans
Both the number of beneficiaries enrolled in 4+ Star plans and the number of 4+ Star plans are increasing, showing that the CMS Star Ratings quality program is working from a quality improvement standpoint and there is a strong demand for higher quality plans. From an Enrollment Weighted Average (EWA)1 perspective, unrounded overall 2020 CMS Star Ratings increased from 4.05 to 4.162 compared to 2019 Star Ratings, a 2.72% improvement. Part C and Part D Summary Ratings also demonstrated improvement, as shown in Figure 1.
Figure 1 – 2018-2020 CMS Star Ratings Trend
The number of Medicare Advantage prescription drug (MA-PD) plans that earned 4 or more Stars in the overall rating increased 23% from 2019, or a total of 52% of plans. And membership continues to consolidate in high-performing contracts, with 81% of MA-PD enrollees in contracts with Star Ratings of 4 or more Stars, an 11% increase from 2019 CMS Star Ratings. The higher performance rate doesn’t happen accidentally; there is a correlation between higher Star Ratings and the amount of MA experience for a given plan. Of the MA-PD plans that received 5 Stars in 2020, 80% had more than 10 years’ experience in the program.
Figure 2 – MA-PD Plans & Membership
Overall industry performance continues to improve and members are staying with higher rated plans. Plans that do not achieve 4 or more Stars and do not receive their QBP potential face increasing pressures to invest in value-based arrangements and thus maintain a strong provider network, fund expanded supplemental benefits for members and grow and retain their membership. With program critics arguing it is time to up the quality standards now that the majority of MA-PD plans have 4+ Stars, the pressure for lower performing plans is likely to grow in the next couple of years.
Not All CMS Star Rating Measures are Equal
Not all measures are equal—what does this mean? CMS Star Rating measures have different weights and have varying impacts on the overall Star Rating of a health plan. So when you are looking at measure-level performance, it is important to look at the heavier weighted measures with a greater impact on your overall Star Rating and focus on achieving better scores in those high-impact measures. Measure-level performance strategies and the prioritization of measures to focus on should vary based upon the potential impact of the measure on the overall Star Rating.
We looked at the three highest and lowest performing CMS Star Rating measures based on the 2020 national average. Rounding out the top three measures were non-HEDIS® measures, with the highest performing measure being Complaints about the Plan. The national average measure-level Star Rating improved nearly 20% from 4.1 to 4.9 Stars over a 1-year span. The Appeals Auto-Forward measure came in second with a 4.7-Star national average and the MPF Price Accuracy measure stayed at 4.8 Stars.
From a measure performance perspective, three non-HEDIS measures outperformed the other measures with Complaints about the Plan national average improving about 16%. The three top performing measures were not top performing for 2019 Star Ratings. The lowest performing measure is Reducing the Risk of Falling with a national average of 2.5 Stars. Medication Reconciliation Post-Discharge, a traditionally low performing measure, remained at the bottom of the list with a national average rating of 3 Stars. The Rating of Drug Plan measure fell from 3.2 Stars in 2018 and 2019 to 3 Stars in 2020, rounding out our lowest performing Star Rating measures. Looking at the weights of these measures, one may wonder why we don’t see higher-weighted measures at the top of this list, but again, not all measures are equal. In addition to having varying weights, they also vary in level of difficulty to attain higher ratings.
Table 1 – Top Performing Measures for 2020 CMS Five-Star Ratings
Table 2 – Bottom Performing Measures for 2020 CMS Five-Star Ratings
|2020 CMS ID
||2018 National Average
||2019 National Average
||2020 National Average
||Complaints about the Plan
||MPF Price Accuracy
|2020 CMS ID
||2018 National Average
||2019 National Average
||2020 National Average
||Reducing the Risk of Falling
||Medication Reconciliation Post-Discharge
||Rating of Drug Plan
CMS Star Rating Measure Cut Point Movement Indicates Relaxing Cut Points
The movement of CMS Star Rating measure cut points can significantly affect the performance of individual measures and overall Star Rating scores. CMS Star Measure Ratings are relative scores. Health plans are judged against their peers and therefore an integral part of the plan is to outperform your peers. Having data beyond that of your health plan or last year’s CMS cut points is critical to more accurately forecast cut points and plan performance.
For instance, say a measure had a 4-Star cut point last year of 77, and this year, you were anticipating the 4-Star cut point to be 79. All year, you were driving toward that goal of 79, but the actual 4-Star cut point fell at 85; that’s a difference of 0.5 Stars. With a triple-weighted measure, it could mean the difference between an unrounded overall rating of 3.74 and 3.76 or a rounded overall rating of 3.5 and 4 Stars.
This year, multiple measures saw significant cut point movement, with 11% (20 measures) having cut point movement of 10 points or more; seven of those measures show cut point movement of 20 or more points. Overall, the ease of 2020 cut points impacted plan performance positively with 400% more plans receiving a higher Star Rating in 2020 than in 2019 and 70% fewer plans receiving a lower Star Rating for 2020 than in 2019.
Difficulty Summary of Part C Measures:
- 41% of measures had 5 Star cut point movement making it more difficult to reach 5 Stars
- 44% of measures had 4 Star cut point movement making it more difficult to reach 4 Stars
Difficulty Summary of Part D Measures
Figure 3 – Cut Point Movement
- 23% of measures had 5 Star cut point movement making it more difficult to reach 5 Stars
- 62% of measures had 4 Star cut point movement making it more difficult to reach 4 Stars
- Medication Adherence measures saw little to no movement in cut points
Categorical Adjustment Index Impact on CMS Star Ratings
CMS continues to apply the Categorical Adjustment Index (CAI) factor to adjust for the average within-contract performance disparity among beneficiaries who receive a low income subsidy (LIS), are dual eligible (DE) and/or are disabled. With CAI, MA plans may have up to three adjustments—overall Star Rating, Part C summary, and Part D summary. Health plans with a higher concentration of LIS, DE, and disabled beneficiaries generally realize greater positive adjustments, however adjustment can be negative as well. Analysis of the CAI reveals that 61 plans were impacted by the adjustment; 12.72% (51) plans saw an increase in overall Star Rating while 2.74% (11) plans experienced a decreased overall rating. Health plans that receive a negative CAI will need to outperform the market on measures to keep up with their competitors.
The constantly evolving CMS Star Ratings program is complex, and the results can be hard to digest without the proper analysis. With these key takeaways, we hope you have a better understanding of the 2020 CMS Star Ratings for MA plans to inform your strategy for 2021 and beyond. As overall industry performance improves, be mindful of measures that will have the greatest impact on your overall Star Rating and leverage comparative data to know where you stand relative to the competition.
For more on the 2020 CMS Star Ratings release, check out this on-demand webinar.
Inovalon calculates EWA based on 2018 membership.
 Inovalon calculations do not account for CMS adjustment for new measures.