CMS recently released two substantive pieces of rulemaking. Both Part II of the Advance Notice of Methodological Changes for Calendar Year 2021 and the Contract Year 2021 and 2022 Medicare Advantage and Part D Proposed Rule outline potential changes to the MA & PDP Star Ratings. There’s a lot of information contained in nearly 1,000 pages of content, but here we focus on changes that might impact CAHPS® and HOS® .
Higher CAHPS Weights. CMS is proposing to further increase the weight of experience/complaints and access measures from a weight of 2 to 4. This is very significant since the weights were just increased to 2 from 1.5 this year. Currently the highest weight is a 3, so CMS is looking to place substantial emphasis on member experience.
The HOS Osteoporosis measure will be fully retired in 2023. Data is currently being collected and is part of the display page, not the star ratings.
Potential new HOS measure. CMS is proposing a new longitudinal measure from the Medicare Health Outcomes Survey (HOS) to complement the measurement of the physical health status of MA beneficiaries. CMS would post the new longitudinal Physical Functioning Activities of Daily Living (PFADL) change measure on the 2021 and 2022 display pages and may consider the measure for the Star Ratings in the future, pending rulemaking.
The PFADL scale combines two physical functioning (PF) questions (limitations in moderate activities and climbing stairs) with the six activities of daily living (ADL) questions to create a Likert-type scale.
PFADL scale scores are created from the baseline and the two-year follow up questions. The newly developed change measure can be interpreted as the percent of function retained by average MAO beneficiaries over two years compared to a maximum decline. In contrast to most HEDIS measures, the PFADL change measure for an MA contract would be its mean change score rather than the proportion passing the measure. The PFADL change score is positively correlated with both physical component summary (PCS) and mental component summary (MCS) scores.
Expanded HOS Denominators. CMS is considering expanding two HOS measures to the under 65 population for two measures: Improving or Maintaining Physical Health and Improving or Maintaining Mental Health.
HOS Calculation Change. CMS is considering possible changes to case-mix adjustment calculations for Improving or Maintaining Physical Health and Improving or Maintaining Mental Health.
HOS Minimum Denominator Change. Improving or Maintaining Physical Health and Improving or Maintaining Mental Health may see changes in the minimum denominator size from 30 to 100.
Adding NPS to Medicare CAHPS. CMS is interested in feedback regarding potentially adding a question related to the NPS or customer loyalty to the MA and PDP CAHPS survey to use to develop a measure in the future for the Part C and D program.
We’ll post updates when CMS finalizes the proposed changes. In the meantime, please contact SPH Analytics if you have questions.