NOTE: Co-published in partnership with Lilac Software. See more on Lilac at the end of the blog.
The Stars road map just got even denser with some proposed changes in the 2027 Advance Notice.
The Stars road map is anything but simple right now. We have a major proposed regulatory reform from the 2027 Medicare Advantage (MA) and Part D proposes rule from November. Much or all of it is expected to be implemented when the final rule comes out in April. We also have the major electronic ECDS measure conversion inflight as well as a push to get all quality programs to a Universal Foundation of measures.
But it is important to track the subtle changes along the way, and these are often buried in the text of the Advance Notices and Final Announcements published each year. While much of the 150-plus page memos are dry rate stuff (but I like it!), buried within these documents are the Stars calendar for the coming year and included measures, important deadlines, and proposed changes, additions, and retirements of both Stars and Display measures. This is a bit of a bible for the coming year and more, which ties closely to the annual rules published wih important Star changes as well. Generally speaking, Star changes need to be published in rules, but the notices and announcements serve as the implementation guide so to speak for plans.
So, let’s outline what is included from a Stars quality perspective in the proposed 2027 Advance Notice of rates and policies. The notice will be finalized in the Final Announcement by April.
Deadline Calendar/Reminders for Star Year (SY) 2027 and SY 2028
For Measure Years (MY) 2025/SY 2027:
- March 31, 2026 – Complaints Tracking Module (CTM) data review requests
- May 18, 2026 – Part D drug measure administrative data review requests
- June 30, 2026 – Part C appeals data review requests
For MY/2026/SY 2028:
- March 31, 2027 – CTM data review requests
- May 18, 2027 – Part D drug measure administrative data review requests
Note that these data review deadlines are before PDE and Appeals (at least for Reopens) have final data completion and before what we think of as the end of the official closeout period (June 30). Thus, MA plans need to thoroughly review data for discrepancies early and call out potential issues with data completed after the deadline.
Star measure additions, removals, and changes for MY 2025/SY 2027
There are six new or updated measures for SY 2027:
- Colorectal Cancer Screening — While the ECDS electronic conversion was not treated as substantive in SY 2026, the measure is being replaced by a respecified version and will be treated as a new measure in SY 2027. The age band will be expanded. That means normal guardrail limitations will not apply. At the 1/2 Star cut point this will be significant based on so-called latency that still exists due to guardrail limitations.
- Care for Older Adults – Functional Status Assessment (COA-FS).
- Concurrent Use of Opioids and Benzodiazepines (COB).
- Polypharmacy: Use of Multiple Anticholinergic Medications in Older Adults (POLY-ACH).
- A statin tolerance exclusion was added to Statin Use for Persons with Diabetes (SUPD).
- For Diabetes Care — Eye Exam (EED), the chart review option was removed.
There are three measures being removed beginning with SY 2027:
- Care for Older Adults – Pain Assessment.
- Medication Reconciliation Post-Discharge.
- Medication Therapy Management (MTM) Program Completion Rate for Comprehensive Medication Review (CMR). Will return o Stars in SY 2029.
There are two weighting changes for SY 2027:
- The Improving or Maintaining Physical Health (IMPH) and Improving or Maintaining Mental Health (IMMH) Health Outcome Survey (HOS) measures move from 1x weight each to 3x weight each.
Other changes for SY 2027 include:
Part C Appeals measures: Data collected through the Part C reporting requirements will be used to confirm the completeness of the Independent Review entity (IRE) data used in the calculation of the Plan Makes Timely Decisions about Appeals and Reviewing Appeals Decisions measures.
Categorical Adjustment Index (CAI) methodology updates: For the first two years post-consolidation, Low Income Subsidy/Dual Eligible and disabled percentages for the surviving contract will be calculated using combined December enrollment for the measurement period of the Star Ratings year across all merged contracts.
The complete measure table for SY 2027 is included on pages 102-105 of the Advance Notice. It includes each measure, the weight, the measurement year, and whether it is counted in Improvement, CAI, and the EHO4all health equity reward. Note that the proposed 2027 MA and Part D rule proposes to expunge EHO4all effective for SY 2027 (retroactively remove it and maintain the Reward Factor).
The disaster grid is published in the Advanced Notice. For SY 2027, there are two disasters that will be in play: The Los Angeles Wildfires in January 2025 and Severe Storms, Straight-line Winds, and Flooding in 10 counties in Texas in July 2025. Note that the LA Wildfires received a benefit in both SY 2026 and SY 2027 regarding CAHPS member satisfaction surveys and will receive the better of the SY 2027 and SY 2026 CAHPS measure-level Star Ratings. In some cases, this would mean the SY 2025 measure-level Star ratings.
Star measure additions, removals, and changes for MY 2026/SY 2028
There are several updated measures for SY 2028:
Statin Therapy for Patients with Cardiovascular Disease (SPC): The measure is undergoing two substantive changes from quality organization NCQA — female age exclusions removed and conversion to electronic ECDS. Thus, the measure will move from Stars to Display in SY 2028 for two years. However, the proposed 2027 MA and Part D rule proposed to eliminate the measure from Stars as of SY 2028.
Medication adherence measures: A risk-adjustment methodology is being implemented in the three medication adherence measures, which will drop to 1x weights for one year. The IP/SNF adjustments will also be removed.
Statin Use in Persons with Diabetes (SUPD): PQA will add a denominator exception for those individuals with diabetes who do not have a prescription claim for a statin but do have one or more prescription claim for either a proprotein convertase subtilisin/kexin type 9 (PCSK9) inhibitor or bempedoic acid. These are recognized therapies for those with a statin intolerance. This will ensure better accuracy of the measure. The person would be identified as in the denominator if they have diabetes. A search of the recognized alternative therapies would be made. If present, the patient would then be removed from the denominator. An analysis found that including the exception criteria had a negligible impact on the year of service (YOS) 2024 SUPD rates overall across all contract types. The change is deemed non-substantive. The change will be implemented for MY 2026.
Polypharmacy: Use of Multiple Anticholinergic Medications in Older Adults (POLY-ACH): PQA clarified how to identify beneficiaries in the eligible population with two or more prescription claims for the same target medication on different dates of service during the measurement period. The same target medication refers to medications with the same anticholinergic active ingredient. This is a non-substantive update and will be implemented in MY 2026.
Call Center measures: The proposed 2027 MA and Part D rule proposes to eliminate the two Call Center measures for SY 2028.
Star measure changes for MY 2027 and beyond
There are a number of proposed meaaure updates for the outyears:
Plan All-Cause Readmissions (PCR):
CMS notes that NCQA is considering updates to include denied claims in identifying index admissions and readmissions as well as re-estimating the risk adjustment model to account for more recent utilization patterns and align with updates to the CMS Hierarchical Condition Category (HCC) model. CMS classifies these as substantive changes that would require two years on the Display Page. The change could be implemented for MY 2028.
Transitions of Care (TRC):
TRC has a number of proposed changes:
MY 2027 – Expansion of the pharmacist type, which is deemed non-substantive.
MY 2028 – NCQA may shorten the timeframe for patient engagement and medication reconciliation post discharge from 30 days to 14 days. It would also add a long-term institution (LTI) flag so members who remain in long term care are not included in the measure. The shortening of the timeframes would be substantive and require rulemaking.
MY 2029 — NCQA intends to develop a new ECDS-reported electronic version of the measure that will consider changes to the current specification based on expert feedback, testing, digital feasibility, and available data standards. NCQA plans to conduct measure testing in 2026 and implement any updates for measurement year 2028. NCQA plans to maintain the current measure alongside the updated measure to allow for transition to ECDS-only reporting in MY 2029. This would not be deemed substantive.
Diabetes Care – Blood Sugar Controlled (GSD):
NCQA is developing an ECDS-reported electronic version of this measure for MY 2027. Prior to implementation, NCQA is conducting testing for ECDS feasibility. Based on findings, NCQA plans to maintain the hybrid measure in HEDIS, in parallel with the ECDS measure, during a two-year transition period (MY 2027 and MY 2028), until the hybrid measure is replaced with the new ECDS-only measure in MY 2029.
CMS describes NCQA’s development of an ECDS-reported version of this measure, with parallel reporting alongside the hybrid version during MY 2027 and MY 2028. The hybrid measure is expected to be replaced by an ECDS-only version beginning in MY 2029.
Display measure updates
There are several update to display measures:
Follow-up After Hospitalization for Mental Illness: NCQA is considering adding Place of Service (POS) 55 — Residential Substance Abuse Treatment Facility to the numerator and removing the remaining mental health provider type requirement to align all behavioral health continuity measures by MY 2027. There is no expected impact to measure performance.
Pharmacotherapy Management of COPD Exacerbation: NCQA is reevaluating the measure to align with updated clinical guidelines. It may be updated or replaced in MY 2027.
Hospitalization for Potentially Preventable Complications: As with PCR, NCQA is considering an update to this measure to allow the use of denied claims for capturing numerator events. In addition, NCQA is planning to re-estimate the risk adjustment models to account for more recent utilization patterns and align with updates to the CMS HCC model. Any updates would be introduced for MY 2028.
Initiation and Engagement of Substance Use Disorder Treatment: NCQA plans to clarify that multi-day substance use withdrawal events must be deduplicated if a claim was generated daily for one withdrawal episode. The change would be effective for MY 2027.
Antipsychotic Use in Persons with Dementia (APD): CMS plans to remove brexpiprazole from the measure, as it now has an FDA-approved indication for dementia agitation. This change would be effective for MY 2026.
Use of Opioids at High Dosage in Persons without Cancer (OHD): CMS plans to update the daily MME calculation methodology in the measure as it relates to transdermal fentanyl patches. This will be effective for MY 2026.
Retirement of display measures
The following display measures are being retired:
Disenrollment Reasons Survey (Part C & D), starting in MY 2027.
Antipsychotic Use in Persons with Dementia for Long-Term Nursing Home Residents (APD-LTNH), starting in MY 2026. CMS plans to retire the APD-LTNH measure and retain the consensus-based APD measure that focuses on all enrollees regardless of setting. CMS previously retired the APD for Community-Only Residents (APD-COMM) measure.
Setting of cut points
CMS says it is continuing efforts to simplify the Star Ratings program and considering methodological enhancements to make the calculations easier to understand and implement. It is contemplating simplifying the methodology for determining measure thresholds. One possible approach being considered would use percentile distribution cut offs to assign measure stars instead of the current clustering methodology for non-CAHPS measures.
The view here is that using percentiles vs. clustering would be more transparent and make
cut points more predictable. Notwithstanding all this, while things might be more predictable, it could also mean CMS uses the new system to “set” the number of contracts at given Star levels.
To learn more about Lilac Software’s Stars and Agentic AI solutions, go to https://lilacsoftware.com .
#medicareadvantage #partd #cms #stars #quality
— Marc S. Ryan
