Section III – Part D
Appendix 5 Summary of Comments on the Draft Call Letter
On February 15, 2013 CMS sent out an Advance Payment Notice and Draft Call Letter to Part C and D sponsors, stakeholders and advocates that described CMS’ proposed methodology for the 2014 Star Ratings for Medicare Advantage (MA) and Prescription Drug Plans (PDP), along with CMS’ responses to comments received on an earlier Request for Comments (November 30, 2012). We received 72 comments on the Draft Call Letter from organizations representing plans, pharmaceutical companies, consumer groups and measurement development organizations. This attachment provides a summary of the comments received and how we addressed these
comments in the final Payment Notice and Call Letter.
Changes in the Calculation of the Part C and D Ratings and the Overall Rating
Summary of Comments:
Many commenters were confused by this proposal and requested clarification and a delay of implementation.
Some were concerned that it would penalize high-performing contracts.
A few suggested that low enrollment contracts should not be incorporated.
Revised Proposed Change:
CMS’ proposal was intended to improve the precision of the calculation of the overall rating and avoid misclassification of contracts. In response to these comments, CMS will delay
implementing any modification until additional research is done. We are concerned that the 4-star thresholds may be contributing to the issue of misclassification. Before we move forward on changing the overall rating methodology, we will give advance notice to contracts on the
proposed methodology through the Advance Notice process. We will also help contracts understand the impact of any proposed changes by calculating their contract scores using the proposed method as part of an HPMS preview.
Four Star Thresholds
Summary of Comments:
Commenters did not have comments on the proposed 4-star thresholds for 2014 for measures that have been part of the Star Ratings for at least 2 years.
Some commenters supported the revised thresholds, which we intend to implement for 2015 Ratings
A few were very concerned that it would be difficult to meet the new thresholds and requested delayed implementation or limiting annual increases to only 1-percentage point.
192 Revised Proposed Change:
The changes we intend to propose for 2015 support the Million HeartsTM initiative. However, the concerns regarding the calculation of the overall rating lead us to evaluate the impact of setting any 4-star thresholds. We therefore do not recommend making any changes to thresholds in the final Call Letter. We will be conducting a comprehensive analysis of the 4-star thresholds.
Low Performer Icon (LPI)
Summary of Comments:
Some commenters supported the modified rules.
Some commenters proposed the LPI be assigned to plans with less than 3 stars for two
consecutive years or to plans with three non-consecutive years less than 3 stars within a five-year period.
A few opposed due to Star Ratings calculation changes or because more plans would be assigned the LPI.
Revised Proposed Change:
We are planning to implement this change that affects few additional contracts. Contracts are responsible for providing adequate care and services across both Part C and D.
Changes to the Methodology of Current Measures
Summary of Comments:
Commenters generally supported the proposed Quality Improvement methodology, the proposal for rounding measure data, the proposal to maintain the current specifications for the High-Risk Medication Use measure for 2014 Ratings.
Most commenters support delaying changes to the drug list until 2015 Ratings, however some requested we further delay until 2016 Ratings.
Commenters supported the proposed addition of two drug classes for the Medication Adherence for Diabetes Medications measure for 2015 Ratings.
Revised Proposed Change:
CMS will implement the proposed Quality Improvement measure changes and rounding methodology. CMS will continue the HRM measure for 2014 Ratings, and intend to apply the updated drug list for 2015 Ratings. CMS also intends to implement the proposed changes to the Medication Adherence for Diabetes Medications measure for 2015 Ratings.
193 Weighting Categories of Measures
Summary of Comments:
The majority of commenters supported maintaining the same weighting categories.
A few commenters suggested that patient experience measures be given a weight of 1 or 3 instead, or measures with any technical specification changes be given a weight of 1.
Revised Proposed Change:
CMS will keep the same weighting categories used for the 2013 Star Ratings.
Integrity of Star Ratings
Summary of Comments:
Several commenters supported this policy.
A few requested more transparency and that it be applied only for egregious violations.
Revised Proposed Change:
CMS will continue its current approach to ensure that data are accurate and reliable.
Disaster Implications
Summary of Comments:
Commenters supported this clarification.
One commenter requested that CMS consider extending the 2/28/13 deadline and establishing a permanent process going forward.
Another commenter asked how national averages and cut points would be affected.
Revised Proposed Change:
Contracts are responsible for contacting CMS in the event of a disaster so that CMS can evaluate circumstances on a case-by-case basis.
Measures Being Removed from Star Ratings and New Measures for the Display Page
Summary of Comments:
Several commenters supported the change.
A few commenters expressed concerns and requested more details about the specifications.
194 Revised Proposed Change:
CMS will provide technical specifications for these measures during the display measures plan preview period. A measure is moved from Star Ratings to display when most contracts are performing at a high level.
Measures to be Continued on Display Page and Possible 2015 Star Rating
Summary of Comments:
A few commenters requested further guidance for the SNP Care Management measure. They had concerns about the methodology and data lag.
There continues to be general support for CMS to evaluate MTM services as a component of the Star Ratings.
Many commenters suggested alternative methods of evaluating MTM outcomes than CMR completion rates. Some commenters questioned the inclusion of LTC residents for MTM services.
Revised Proposed Change:
CMS will move forward with these as display measures and will provide additional guidance as needed. The current measure of MTM CMR completion rate is the first phase of evaluating MTM services, and CMS will consider other outcomes-based MTM measures once endorsed by measure development organizations. MTM regulatory requirements, such as the inclusion of LTC residents, are outside the scope of Star Ratings and Call Letter.
Forecasting to 2015 and Beyond
Summary of Comments:
Some commenters contended that the Disenrollment Reasons survey would be subjective.
Some commenters had specific questions about the survey questionnaire and methodology.
Revised Proposed Change:
CMS is currently in the survey implementation stage. More information will be shared with contracts in the near future.
Changes to Measure Specifications or Calculations
Summary of Comments:
All commenters were supportive of CMS using NCQA’s specifications for Breast Cancer Screening.
195
For the HOS calculations, commenters were concerned about the reliability and validity of the measures. One commenter urged CMS to work with the industry to develop these measures.
Revised Proposed Change:
CMS always welcomes feedback on these or any measure at any time. As stated in the Call Letter, CMS is testing the reliability and validity of an alternative scoring methodology for HOS.
Measures for Informational Purposes Only
Summary of Comments:
Commenters preferred that CMS use objective data instead of what they viewed as subjective survey data.
One commenter contended that health plans have little control over whether a provider uses EHR.
Some commenters did not want these measures to be included as display measures.
Revised Proposed Change:
These CAHPS surveys are for informational purposes only and should provide plans valuable feedback on how their beneficiaries feel about different aspects of the healthcare provided to them.