To provide health care organizations with the full ability to respond to the COVID-19 pandemic, the Centers for Medicare & Medicaid Services has issued temporary regulatory waivers and new rules to lift administrative burdens. Those changes involve data collection for HEDIS®, CAHPS, and the Star ratings program.

CMS announced it will provide temporary relief from paperwork, reporting, and audit requirements for health care providers and organizations, including Medicare Advantage and Part D plans, so they can fully focus on providing care to Medicare and Medicaid beneficiaries affected by COVID-19.

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Here is a summary of those changes:

  • Medicare health plans won’t have to submit Healthcare Effectiveness Data and Information Set (HEDIS) 2020 data covering the 2019 measurement year. Instead, Medicare health plans can use any HEDIS data that they have collected for their internal quality improvement efforts.
  • Medicare health and drug plans also won’t be required to submit 2020 Consumer Assessment of Healthcare Providers & Systems (CAHPS) survey data. Instead, Part C and D plans can use any CAHPS survey data collected for their internal quality improve­ment efforts.
  • CMS announced that the Health Outcomes Survey, administered by the National Committee for Quality Assurance as a component of HEDIS data collection, will be postponed to late summer.

Data collection changes for 2021 Star ratings calculations

In addition, CMS said it will now use last year’s HEDIS measures scores and ratings from the 2020 Star ratings (based on care delivered in 2018) and CAHPS measures data scores and ratings from the 2020 measure-level Star ratings for 2021 Star ratings.

CMS doesn’t plan to make changes to the measurement period and data for all other measures if there is no health and safety risk from COVID-19 to collect the data.

However, the agency said that if the outbreak prevents it from validating data or there are systemic data integrity issues for any other measures, it would replace 2019 data that has quality issues due to COVID-19 with the measure-level Star rating and score from the 2020 Star ratings.

In addition, if the outbreak leads to CMS only focusing on essential functions and/or it can’t calculate the 2021 Star ratings, it plans to use the 2020 Star ratings for 2021.

If 2021 is the first year that a new health plan would receive a Star rating, the agency will not have enough data to assign a rating. Those health plans will be considered new for 2022.

Changes to 2022 Star ratings calculations

For 2022, CMS expects Medicare Advantage contracts to submit HEDIS data in June 2021, and Medicare Advantage and Prescription Drug Plan contracts to administer the CAHPS survey in 2021 as usual so there is not a concern about data collection for the 2020 performance period.

However, to address concerns about overall performance in 2020, CMS said it will delay implementation of the 5-percentage point cap so that cut points for the 2022 Star ratings can change by more than 5 percentage points if national performance declines overall as a result of the outbreak.

CMS said it will calculate the Part C and D improvement measure scores for the 2022 Star Ratings as codified, but “recognizes that the COVID-19 outbreak may result in a decline in industry performance, therefore expanding the ‘hold harmless rule’ to include all contracts at the overall and summary rating levels.”