In an August 5 memo to all Medicare Advantage (MA) plans, the agency announced that the COVID-19 public health emergency significantly impacted the validity of measures related to physical and mental health currently used in the Star Ratings.

The two Health Outcomes Survey (HOS) outcome measures, Improving or Maintaining Physical Health and Improving or Maintaining Mental Health, which are triple-weighted, assess an MA organization’s ability to improve or maintain the physical and mental health of its enrollees over time, based on baseline and follow-up survey data collected at the beginning and end of a two-year period.

The measures rely on models to predict expected changes in physical and mental health status and mortality from baseline to follow-up, based on relative contract performance. However, CMS said that the data collected for these measures during the COVID-19 public health emergency also reflect significant and disparate effects of COVID-19 on enrollees’ physical and mental health status and mortality. CMS is unable to accurately isolate or control for these variations within the statistical models underlying these two measures.

As a result, CMS said the validity of the models is compromised and it can’t accurately measure change in beneficiary health status over time for these two measures. However, the cross-sectional HEDIS measures derived from the HOS will be reported as usual in the 2022- and 2023-Star Ratings because these are process measures, collected at one point in time, and their calculation is not affected by the statistical modeling issue caused by the pandemic.

“Due to the pervasive way in which COVID-19 has undermined and will continue to undermine the validity of the two HOS outcome measures for the 2020 and 2021 follow-up measurement periods, CMS will calculate the 2022- and 2023-Star Ratings without the use of Improving or Maintaining Physical Health and Improving or Maintaining Mental Health,” Amy Larrick Chavez-Valdez director, Medicare Drug Benefit and C & D Data Group, wrote in the August 5 memo.

RISE West 2021

The agency will move the two measures to the display page on with a note that the comparisons are pre- and post-pandemic and that the measures are not being included in the 2022- and 2023-Star Ratings due to validity concerns related to the COVID-19 public health emergency.

Chavez-Valdez said that MA organizations will receive beneficiary-level data for use in quality improvement and to help them better understand the impact of the pandemic on Medicare beneficiaries’ physical and mental health.

Melissa Newton Smith, executive vice president, Consulting & Professional Services at HealthMine, said that the removal of the two HOS measures will no doubt cause celebrations across the MA industry but she warns plans to beware. “This exacerbates the artificial inflation of 2022 Star Ratings, which likely portends looming quality bonus program payment reform,” she said.  

To learn more about the future of Star Ratings, Newton Smith will be moderating a discussion about new measures and weights at RISE West, on Wednesday, Sept. 1. Click here for more information about the hybrid event.