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MMP Star Program Coming to Fruition

MMP Star Program Coming To Fruition

The Centers for Medicare and Medicaid Services (CMS) continues its push to bring STAR quality performance programs to all lines of business. The program in the Medicare Advantage (MA) and Part D programs is long-standing, and earlier this year CMS finalized its Medicaid Uber Rule, which promises to transform the state entitlement and bring about quality through a similar performance assessment program. Now, CMS has announced further progress in establishing the program for the Medicare-Medicaid Plan (MMP) dual demonstrations program, currently ongoing in about a dozen states.

On November 6, 2015, via an HPMS memo, CMS outlined its long-term objectives and plans for an MMP Star program. We wrote about the overview in our February 4, 2016, Strategic Insights blog. This week (via a June 15, 2016 HPMS memo titled MMP Quality Rating and Performance Data Strategy Update), CMS summarizes and comments on feedback received on its MMP STAR proposal from November 2015, announces its 2016 MMP public display of MMP measures, and published proposed 2017 MMP measures. These 2016 and 2017 approaches serve as interim steps, as the long-term plan is developed and adopted.

Commenters generally indicated that they supported a distinct MMP rating system as opposed to being lumped together with the current Medicare Advantage system. Indeed, everyone agrees that the current MA Star program has some built-in discrimination against Special Needs Plans (SNPs) due to the significant socio-economic, health literacy, and multiple co-morbidities faced by enrollees in these plans. For 2017, CMS announced it was adopting an interim adjustment to certain STAR measures to adjust for these issues, which disadvantage SNPs when compared with mainstream MA plans. CMS will likely propose a formal system later to address the inequities in the main program or potentially place SNPs into the MMP plan being developed. Suffice it to say, CMS is fully on board for a specific MMP assessment program.

There also is some concern about how survey measures will impact MMP STAR ratings given some of the same socio-economic and morbidity issues. CMS will work with stakeholders on this.

Commenters also emphasized the need to align the MMP program with existing STAR and state quality programs as much as possible. Without this, plans might have three different systems (Medicare, Medicaid, and MMP) to report on. CMS agrees. But, there are unique features of MMPs that will require always having at least a subset of MMP-specific measures. In addition, while the MMP plans seek to align the Medicare and Medicaid funding streams and coordinate treatment, the MMPs in the demonstration states can be very unique from state to state. Some focus largely on acute medical integration, while others introduce some limited chronic and long-term care (LTC) services, and still more have full -fledged medical and acute LTC services embedded. Therefore, long-term care measures will likely vary by state, as will behavioral health, substance abuse, and some other measures.

Commenters asked whether MMP Star will be placed on top of existing quality withhold arrangements and CMS notes that any Star payment system will replace the existing construct.

Commenters asked whether MMP Star will be placed on top of existing quality withhold arrangements and CMS notes that any Star payment system will replace the existing construct.

2016 Measures Posting

For 2016, CMS proposes to use all Part C and Part D STAR ratings measures that are reported by MMPs except for five (5) measures that are not relevant or overlap with MMP-specific measures. Data on the following MMP-specific measures will be posted:

  • Antidepressant Medication Management
  • Care Transition Record Following Inpatient Discharge
  • Screening for Clinical Depression and Follow-up
  • Follow-up After Hospitalization for Mental Illness
  • Initiation and Engagement of Alcohol and Other Drug Dependence Treatment

With the exception of the Consumer Assessment of Healthcare Providers and Systems (CAHPS) measures, CMS will post the MMP-specific results for each measure alongside the all-MMP and state-MMP averages for that measure. In this way, CMS proposes to create comparisons between the various plans within and between the pilot states. Survey measure will only have the all-MMP comparison.

Comparing between states worries many MMP plans, given the significant differences that do exist between states, including both healthcare and community services infrastructure.

2017 Proposed Measures Set

In addition to relevant Part C and Part D measures, CMS proposes the following:

MMP Specific:

  • Comprehensive Health Risk Assessment
  • Care Plan Completion

Additional MMP Survey:

  • Ease of obtaining healthcare equipment
  • Ease of obtaining personal care or aide care
  • Satisfaction with coordination of care

Long-Term Progress

CMS has hired an expert entity to assist it in developing MMP measures. CMS has put a priority on addressing gaps in the current MMP measure set, including for delivery of long-term services and supports, behavioral health, and treatment of substance abuse disorders. Three likely measures on the long-term care assessment side will include:

  • Admission to an Institution from the Community — The number of admissions to an institution (nursing facility or ICF/IID) from the community during the measurement year per 1,000 beneficiary months.
  • Successful Discharge to the Community after Short-Term Institution Stay — The percentage of institution admissions (nursing facility or ICF/IID) that result in successful discharge to the community (community residence for 30 or more days) within 100 days of admission.
  • Successful Discharge to the Community after Long-Term Institution Stay — The percentage of long-term (101 days or more) institution residents (nursing or ICF/IID) who are successfully discharged to the community (community residence for 30 or more days).

In the main Star program, the readmission measure has been a struggle for plans. CMS is also tapping a Preventable Admissions measure in the future for the main program as well. These five measures will clearly challenge MMP plans moving forward.

Marc Ryan

Marc S. Ryan serves as MedHOK’s Chief Strategy and Compliance Officer. During his career, Marc has served a number of health plans in executive-level regulatory, compliance, business development, and operations roles. He has launched and operated plans with Medicare, Medicaid, Commercial and Exchange lines of business. Marc was the Secretary of Policy and Management and State Budget Director of Connecticut, where he oversaw all aspects of state budgeting and management. In this role, Marc created the state’s Medicaid and SCHIP managed care programs and oversaw its state employee and retiree health plans. He also created the state’s long-term care continuum program. Marc was nominated by then HHS Secretary Tommy Thompson to serve on a panel of state program experts to advise CMS on aspects of Medicare Part D implementation. He also was nominated by Florida’s Medicaid Secretary to serve on the state’s Medicaid Reform advisory panel.

Marc graduated cum laude from the Edmund A. Walsh School of Foreign Service at Georgetown University with a Bachelor of Science in Foreign Service. He received a Master of Public Administration, specializing in local government management and managed healthcare, from the University of New Haven. He was inducted into Sigma Beta Delta, a national honor society for business, management, and administration.

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