C-TAC recently submitted a comment letter to CMS on the Advance Notice of Methodological Changes for CY 2025 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies. Here are C-TAC’s comments on pertinent measures in the proposed Advance Notice:
Changes to Existing Star Ratings Measures for the 2025 Measurement Year and Beyond
- Cross-cutting: Gender-Affirming Quality Measurement in HEDIS (Part C) – We support this effort as a way to both fully capture all eligible individuals for these interventions and as a sign of gender affirmation. We support making this a cross-cutting effort and applying it to all other appropriate measures in the Medicare program as we believe that will help address disparities and improve access.
- Care Coordination (Part C) – We support this measure effort but have concerns that the language is very doctor-specific in some of the questions. The data shows that advance practice providers are increasingly delivering primary care in the US. For instance, more than 70% of the 355,000 licensed NPs in the U.S. practice in primary care. Therefore, patients may see a nurse practitioner or physician assistant for their care and so may be confused by questions about “their doctor.”
We also suggest that the phrase “prescription medication” in the second question be replaced with “all medications” as many people may be taking over the counter medications and supplements which could also affect their health. A medication review should include those as well as any prescription medications.
- Follow-Up After Hospitalization for Mental Illness (Part C) – We support broadening the kinds of mental illnesses that should be included in this measure to ensure it has meaningfully measures for the range of mental health issues members are experiencing. We have all become more aware of and concerned about the prevalence of mental health issues and agree that follow-up from any hospitalization for them should include all possible members involved.
- Social Need Screening and Intervention (Part C) – We support social need screening and again suggest that caregiver burden or stress also be eventually screened for since that can affect the management of the patient’s medical condition and prompt emergency room visits if not addressed. Of course, screening is of little value without appropriate interventions for issues identified by screening, so the metric should end up monitoring intervention and successful completion of the intervention as well.
- Use of Opioids at High Dosage in Persons Without Cancer (OHD) / Use of Opioids from Multiple Providers in Persons Without Cancer (OMP) / Concurrent Use of Opioids and Benzodiazepines (COB) / Initial Opioid Prescribing for Long Duration (IOP-LD) (Part D) – We support testing an update to exclude members more broadly with cancer-related pain treatment from these opioid-related measures as that is in line with the updated 2022 Centers for Disease Control and Prevention (CDC) Clinical Practice Guideline for Prescribing Opioids for Pain, which we also supported. Opioids for chronic pain can be necessary for some cancer survivors and so these patients and others with cancer-related pain should be excluded from these measures so as not to penalize them or their providers.
Potential New Measure Concepts and Methodological Enhancements for Future Years
- Social Connection Screening and Intervention (Part C) – We support the development of a new measure that assesses the percentage of members aged 65 and older who were screened using prespecified instruments, at least once during the measurement year for social isolation, loneliness, or inadequate social support and received a corresponding intervention if they screened positive. C-TAC has members and partners who are specifically focused on this issue, and we agree that measuring it will help identify it as a health issue warranting further action.
- Functional Status Assessment Follow-Up (Part C) – We support NCQA exploring the development of a new measure to assess follow-up after a Functional Status Assessment. Functional status is an important factor in quality of life and needs to be consistently measured, and then addressed, in all Medicare programs including MA.
- Medicare Plan Finder Drug Pricing Measure (Part D) – We support consideration of such a measure as it is unfortunate that some plans may be submitting artificially high or low prices to display during the annual enrollment period. Our recommendation is that any pricing information provided to potential members be clear so that members can make fully informed decisions on which plan is best for them when pricing is a factor.
Additional Measure Concepts for Consideration
In addition to the measures provided in the proposed Advance Notice, we suggest the following additional measure concepts:
- Felt heard and understood – We recommend the patient-reported 2024 MIPS Measure #495: Ambulatory Palliative Care Patients’ Experience of Feeling Heard and Understood quality measure that was added to the measure sets for family medicine, internal medicine, and hematology/oncology specialty sets in the latest Physician Fee Schedule. It would also be beneficial in the MA program as it focuses on communication between the person and their medical provider.
- Palliative care access and utilization – MA members with serious illness would benefit from the inclusion of home-based palliative care services in their care. By palliative care, we mean the CMS definition of “Patient and family-centered care that optimizes quality of life by anticipating, preventing, and treating suffering. Palliative care throughout the continuum of illness involves addressing physical, intellectual, emotional, social, and spiritual needs and to facilitate patient autonomy, access to information, and choice.” Therefore, we suggest adding a measure to the MA program about palliative care referral or access to palliative care and how many of those with serious illness are utilizing these important services.
- Timely and appropriate referral to hospice – We appreciate the work the VBID model is doing around testing access to hospice for MA members. At the same time, we suggest adding a measure to the MA program to ensure that a hospice referral is considered for members who need and qualify for hospice and that the member’s eligibility for hospice be assessed and hospice offered when appropriate. A claims-based outcome measure could begin to capture basic information like the percent of model members that transition to hospice and of those hospice patients, whether referral to hospice was timely based on hospice length of stay, i.e., less than seven days, etc.
