This week, the Medicare Rights Center submitted a response to a Centers for Medicare & Medicaid Services (CMS) request for comment on Enhancements to the Star Ratings for 2018 and Beyond in advance of the draft 2018 Call Letter. The proposed changes are intended to tweak the measures and methodology of the star rating system to better capture performance, including changes to the way audit and enforcement actions affect star rating results.

The Star Rating program gives information to people who are new to Medicare or who are exploring their Medicare options about the quality and performance of the Medicare Advantage and Part D prescription drug plans available to them. The program also rewards high-performing MA plans with payment bonuses, and identifies persistently low performing plans. The ratings are derived from many sources, including patient, clinician, and plan surveys, plus regular monitoring activities by Medicare.

We continue to support CMS’ efforts to provide better information for beneficiaries on the Star Rating system. Medicare Rights’ comments highlight that the current methodology for determining Star Ratings can create a disconnect between the Star Ratings and audit results, where plan audits flag deficiencies but there is no resulting decline in the plan’s ratings.

To address this, CMS proposes several new mechanisms to incorporate audit results, including existing sanctions, into the star ratings formula. Medicare Rights’ comments urge CMS to re-institute a automatic reduction, in the form of a one-star demotion, for plans who are found to be in such significant violations of Medicare rules that enrollment sanctions are instituted (meaning the plan cannot enroll new members until the issue is resolved) and to more heavily weight other types of poor-audit result consequences, including civil monetary penalties, in the baseline Star Rating formula.

Read the comments.