Experts Say COVID-19 Pandemic Will Have Lasting Impact on CMS Star Ratings


Policy changes impacting the star ratings for 2022 include additional flexibility provided during the COVID-19 pandemic and a revised Extreme and Uncontrollable Circumstances policy.

Because the Centers for Medicare and Medicaid Services (CMS) issued temporary waivers and new rules to give health plans flexibility early in the COVID-19 pandemic, these changes will impact the 2022 and 2023 Part D and Part C star ratings, according to an expert panel at the Pharmacy Quality Alliance 2021 Annual Meeting.

During the session, speaker Rex Wallace, MBA, outlined some changes for the star ratings and what health plans can anticipate over the next 2 years. He emphasized that the 2022 star ratings are calculated based on plans’ performances in 2020, using data collected during 2021. Similarly, the 2023 rates will represent plans’ performances in 2021 and use data from 2022.

Policy changes impacting the star ratings for 2022 include additional flexibility provided during the COVID-19 pandemic; the revised Extreme and Uncontrollable Circumstances (EUC) policy; and delays in the implementation of some policies.

Speaker David Dodge, Medicare Stars program director with Cambia Health Solutions, said the EUC policy was implemented to relieve some challenges created by the international pandemic. Under the 60% rule, Dodge said CMS would not utilize data from plans in areas that have had a natural disaster. Because the entire country was impacted by the end of March, however, CMS relaxed the 60% rule to allow the “higher of” provision to apply. Dodge said this should have a beneficial impact for plans in the 2022 star ratings.

Wallace also outlined several policies that were delayed due to the pandemic. For instance, CMS had planned to implement cut-point guardrails in order to address plans’ frustrations with the unpredictability of cut points but decided to delay this implementation to avoid penalization because of 2020 performances. Similarly, the Controlling Blood Pressure measure was scheduled to return for star ratings in 2022 but was delayed by a year due to challenges around data collection.

Finally, Wallace said the Health Outcomes Survey was delayed by a few months in 2020 and CMS has decided to make this a permanent change. Whereas the survey is typically conducted between April and July, it will now be conducted between August and November moving forward.

Some of these impacts will also be seen in the 2023 star ratings, according to Wallace. He said plans should not expect EUC relief except perhaps in the Health Outcomes Survey, although Dodge added that he is still unsure how the survey will be calculated in the 2023 ratings. The Controlling Blood Pressure measure will be returning with a timely change allowing patients with digital devices to utilize them to close gaps in care.

Some measures are still delayed, however. For example, Wallace said the Plan All-Cause Readmissions measure is delayed by a year and will be implemented for star ratings in 2024.

Furthermore, Member Experience measures are rising to a rate of 4 for the 2023 star ratings, Wallace said, making up more than half the weight of the overall ratings. This could have major impacts when considering the important roles that plans played during the COVID-19 pandemic. Wallace added that health plans could benefit greatly from these changes.

In addition to these changes to the star rating system, the panelists discussed some impacts of the pandemic that proved to be less alarming than originally believed. Dodge said there were many fears that all of the star measures would fail, but he said that fear has not come to fruition based on the data they have so far. Panelist Chris Powers, PharmD, agreed, pointing out that although there was a declining number of new users across several key drug classes, utilization increased for all of these therapeutic areas.

“We know that health plans, pharmacies, [and] pharmacists really went above and beyond to make sure their customers had access to medications during the pandemic,” Powers concluded.


Wallace R, Dodge D, Powers C, Hines L. COVID-19’s Impact on Quality. Presented at: Pharmacy Quality Alliance 2021 Annual Conference. May 13, 2021.

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