To say the events of the last two years had an unprecedented and unconventional impact on health plans would be an understatement. Fast forward from March of 2020 through the better of logic within The Extreme and Uncontrollable Circumstances Policy producing temporarily inflated 2022 Star Ratings to today. While we wait for either the end or extension of the current Public Health Emergency (PHE), the Centers for Medicare and Medicaid Services (CMS) continues to work tirelessly to further its pledge to put patients first in all programs.
To truly put patients first, however, you have to address their needs and provide support to the plans, practitioners, and communities who care for our most vulnerable populations. Back to the traditionally timed release of the 2023 Medicare Advantage and Part D Advance Notice Part II, CMS provided plan sponsors with a sneak peek at its next sizeable agenda with an emphasis equity! This takes me back to when we first read about proposed weight increased for CAHPS® and the other member experience measures. Back when it felt nearly impossible and so much more difficult than managing numerator compliance for HEDIS® and Adherence measures. But we started taking better care of our members and alas, here we are looking at all of those 4s in the weight column of 16 separate experience measures and hoping it all shakes out in favor and balances the expected deflation in post-pandemic performance metrics.
CAHPS® and the Member Experience
CMS makes good on its promise to lend a bigger voice to the beneficiary as it proceeds with the increased weight of its member experience measures, including the Consumer Assessment of Health Plans and Systems (CAHPS®) survey. The 2022 MA-PD CAHPS survey fielding began last week and I’m sure teams are eagerly awaiting even the earliest peek at performance from their survey vendors ahead of Westat reports later this summer while the rest of us will have to wait until public data becomes available in early October. Even the best and most robust regulatory and off-cycle surveys will only represent a small percentage of members at one moment in time. Plans need more experiential and real time data around common and frequently used benefits that scales not only the entire member population, but the entire member year. mPulse has developed an event-based check-in program that not only gathers valuable member experience and sentiment data, but also has the ability to address dissatisfaction and solve common pain points in real time using its patented natural language understanding and conversational messaging.
The Extreme and Uncontrollable Circumstances Policy
As expected, The Extreme and Uncontrollable Circumstances Policy provided additional COVID-19 relief and over inflated performance numbers that will feel like a one-time get out of jail free card with the ‘better of logic’ that will not be in play for 2023 Star Ratings. This ‘better of’ method produced inflated performance numbers that will be difficult to sustain in future years. As experience continues to reign supreme, plans should prepare everyone from members to senior leadership for potential disruption and work to find ways to offset the potential loss of the one-time inflated bonus payments.
No new measures for 2023 and some moving to the display page
With no new measures for 2023 and some moving to the display page for a few years, plans will have the opportunity to continue efforts to close gaps, connect members to appropriate care, and review their data for another year. Controlling Blood Pressure makes its return to the active page with a 1x weight while Plan All Cause Readmission remains on display for one more year before returning with a 1x for 2024 Stars. Two key HOS measures, Improving or Maintaining Physical Health & Improving or Maintaining Mental Health will see their time on the display page for 2022 & 2023 as they were too disrupted by COVID-19.
HEDIS and Telehealth
HEDIS and Telehealth seem to be here to stay and work together. According to the American Journal of Managed Care, telehealth claim lines increased 3.060 percent nationally from October 2019 to October 2020. As members seek care outside of the traditional office setting, providers and payers still have a need and obligation to capture the full burden of illness and these updates include additional code sets to be allowed for measure inclusion or exclusion when captured via telehealth visits alone. This is just another example of how members, plans, and providers are embracing digital technologies. We’ll keep an eye on these flexibilities as the House recently extended virtual care flexibilities beyond the public health emergency.
Is Health Equity the new Experience?
CMS provided information on the potential development of five new equity related measures for Parts C and or D.
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- Driving Health Equity (Part C and D)
- Stratified Reporting (Part C and D)
- Health Equity Index (Part C and D)
- Measure of Contract’s Assessment of Beneficiary Needs (Part C)
- Screening and Referral to Services for Social Needs (Part C)
After two wild years of recycling data and rates due to COVID-19 to the temporarily over-inflated 2022 Part C & D Star Ratings due to the expansive extreme and uncontrollable circumstances policy, 2023 proposed changes seem to be minimal and mild in comparison. The last handful of years have had plans focusing heavily on improving their member experience with 2023 Stars rounding out the increased weights from 1.5x to 4x. Accounting for just over 50% of the plan’s overall Star Ratings weight, experience will remain top of focus for the foreseeable future. But no time to get comfortable because equity and social determinants are hot on experience’s heels with more than a handful of related measures and methodological enhancements. Proposed changes and new measure concepts must go through federal rulemaking and stabilize on the Display Page for a minimum of two years before becoming an active Star Ratings measure. mPulse has developed solutions to address and promote social determinants as well as stratify your member data within our engagement solutions to support and map to internal efforts.
It’s never too late to develop or enhance your member engagement strategy. How will you continue to wrap your arms around your members as we (hopefully) move from pandemic to endemic and beyond?
