We write to express our support to members of the Senate and to members of the Senate Finance Committee for encouraging the Centers for Medicare & Medicaid Services (CMS) to take steps to alter the Star ratings program to account for underlying differences in Medicare Advantage (MA) plans’ enrolled populations. Forty Senators submitted a letter to Administrator Tavenner on February 3, 2015, and this issue was also raised during the Senate Finance Committee’s February 4 hearing. We believe that the Star ratings program, in its current form, disadvantages health plans that enroll dual eligible beneficiaries. We applaud the Senators for urging CMS to use its existing regulatory and administrative authority to improve the Star ratings program so that the quality of care MA plans provide to dualeligible beneficiaries can be accurately measured and compared across plans.

Dual-eligible beneficiaries are among the poorest, sickest, and most costly individuals to both the Medicare and Medicaid programs. They often fall through the cracks between the two programs, and many of these beneficiaries experience uncoordinated care in Medicare and Medicaid fee-for-service (FFS). D-SNPs are an opportunity for these beneficiaries to receive better coordinated care and higher quality of care than they would otherwise receive through FFS. Unlike other types of MA plans, D-SNPs exclusively enroll and focus their provider networks, benefit packages, and care management resources specifically on dual-eligible beneficiaries.

The inability of the Star ratings program to accurately assess and compare quality measures for dualeligible beneficiaries is a consumer issue as well as a plan issue. Dual-eligible beneficiaries will lose if their health plans – particularly those that integrate all of their Medicare and most of their Medicaid benefits – are no longer financially able to continue serving them due to low reimbursement on account on inaccurate Star ratings.

We support a Star ratings program that evaluates and compares all MA plans based on the quality of care they furnish, rather than on the underlying characteristics and needs of their enrollee population.

We have asked CMS to improve the program by:

1. Using quality measures that are appropriate for dual-eligible beneficiaries with complex health, behavioral, and cognitive needs;

2. Reporting and applying quality ratings of D-SNPs at the plan level instead of the contract level; and

3. Comparing D-SNPs to other D-SNPs that enroll similar populations.

We have also asked Congress to require the Government Accountability Office (GAO) to conduct a study to determine how the Secretary could change the Star ratings program to accurately compare the quality of care provided by individual D-SNPs (and D-SNPs as a whole) to the quality of care dual-eligible beneficiaries receive under Medicare FFS and other MA plans with similar populations.

It is a high priority for our D-SNP member plans that the quality of care they provide to their dualeligible enrollees is accurately measured and reported to consumers. We will continue to work with our member plans to identify ways to improve the accuracy of the Star ratings program. We hope that the experience of our member plans in serving some of the most complex, challenging, and costly Medicare and Medicaid beneficiaries is a resource to the Congress and to CMS as the MA program is improved, so that all Medicare beneficiaries have the opportunity to receive better quality of care through this program.

ACAP is prepared to assist with additional information, if needed. If you have any additional questions please do not hesitate to contact Christine Aguiar at (202) 204-7519 or caguiar@communityplans.net.

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