Thoughts on CMS’ Future Expectations of CMR Completion Rates for Medicare Part D Plans
Comprehensive Medication Reviews (CMR) changed from a Display Measure to a STAR Measure in 2014, thus becoming the first STAR measure established by the Centers for Medicare and Medicaid Services (CMS) to specifically evaluate the quality of a Medication Therapy Management (MTM) Program.
Clinical Support Services, Inc. (CSS) used CMS’ 2015 Part C & D Medicare Display Measures output to conduct a frequency analysis of where plans currently stand with regard to CMR completion rates. Of the 540 plans that reported a CMR completion rate, 59.2% (320) rank in the bottom two (2) deciles. Only nine (9) plans rank in the top two (2) deciles.
So how will CMS assign a STAR rating to this new CMR measure?
Unfortunately for Medicare Part D plans, CMS has yet to provide a definitive answer to this question. But some statements in the Advance Notice for the 2016 Part D program provide a bit of insight.
Pg 84. “…the use of pre-determined thresholds violates our principle of assigning stars that maximize the difference between star categories.”
Pg 84. “…sponsors on average have more significant levels of improvements in Part C and D measures without pre-determined thresholds.”
Pg 85. “…we will proceed as originally planned and as announced in prior Call Letters and eliminate all pre-determined 4-star thresholds for the 2016 Star Ratings.”
Pg 87. “Sponsors are reminded that they should not restrict their MTM eligibility criteria to limit the number and percent of beneficiaries who qualify for these programs and to whom they must offer a CMR.”
What do these comments mean to us at CSS?
Here are a couple of things that strike us about these comments. Remember the old joke about the two men being chased by a bear and the one man stops to take off his shoes and put on his sneakers? His friend says, “What the heck are you doing? Do you really think sneakers will help you out-run a bear?” to which his friend replies, “I don’t need to out-run the bear I only need to out-run you!”
It appears that simply “outrunning” competing plans will not be good enough with the CMR measure.
With regard to CMR completion rates, CMS doesn’t want winners and losers. They want all winners.
CMS believes that the CMR measure is a good evaluation of the quality of an MTM program. Remember, the Acumen report that CMS released in January 2013 concluded that:
- “good things” (i.e. increases in quality) happen when you do some type of MTM
- “better things” (i.e. increase in quality AND decrease in costs) happen when you do CMRs
- the “best things” (i.e. increases in quality AND decreases in cost where the decrease in cost overcomes the cost of quality) happen when you pursue CMRs aggressively.
We believe that this first year CMS will be clustering plans into STAR measure categories in a way that there is a lot of incentive to improve. Likely, this year the majority of plans will be 3 STARs and below.
Based on the Acumen report conclusions, a CMR completion rate in excess of 50% might be required for a plan to be in a 4 or 5 STAR position. This will require a lot of experimenting with methods beyond the traditional telephonic or face-to-face CMRs.
Finally, we see a warning from CMS that tells plans don’t try to improve your CMR completion rates by lowering your number of MTM eligibles.
James Notaro is the Founder and President of Clinical Support Services. He can be reached at 716.541.0273 x101 or firstname.lastname@example.org.
James Notaro, RPh, PhD