One of the surprises in the release of plans’ Star Ratings results for the 2019 open enrollment season was that Star Ratings around Part D adherence scores, on average, slipped. [1] 

The Centers for Medicare & Medicaid Services (CMS) includes three adherence measures in the Part D domains including:

Medication Adherence Case Study

Prior to the release of this latest Star data, BluePeak was working with a Medicare Advantage plan that was targeting improvement on the Part D adherence measures, which had declined in a prior measurement period. This Plan targeted these measures as part of an overall strategy to improve their Star summary rating, recognizing that measures like these are weighted a 3, as an intermediate outcome measure, in the Star ratings. Lack of adherence or improper medication use relative to diabetes, hypertension or hypercholesterolemia can result in poor health outcomes as well as increased cost of healthcare, which is why they are targeted and measured by CMS. 

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[1] Fact Sheet – CMS 2019 Part C and D Star Ratings -Based on the 2019 Star Ratings published on Medicare Plan Finder (MPF) on October 10, 2018. For details on the Medicare Advantage (MA) and Part D Star Ratings, please refer to the 2019 MA Part C & D Star Ratings Technical Notes available at http://go.cms.gov/partcanddstarratings .

Is Your Plan Ready For The New Year?

Don’t breathe a sigh of relief just yet. While 1/1 is an important day for plans, there are several changes for this year that will require testing and oversight beyond 1/1.

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Prepared to Implement the CMS Preclusion List Requirement?

Along with the new year also comes a new CMS requirement known as the Preclusion List. This requirement was adopted in the April 2018 final rule as an alternative to the rescinded Medicare enrollment requirement that mandated contracted providers to enroll in Medicare to ensure the prescriptions they were writing would be covered under Part D.

CMS has now extended the preclusion guidance to providers and entities for medical benefits as well as providers writing prescriptions. CMS published guidance outlining how to implement and comply with the newly adopted Preclusion List requirements in an HPMS Memo on November 2, 2018. The requirement defines that contracted and non-contracted providers will not be eligible to receive payments from a Medicare plan, 1876 Cost Plan, or PACE organizations if they are included on the Preclusion List. Additionally, this will also be a requirement for providers writing prescriptions for Part D drugs to be covered by a Part D plan. 

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