Measure for measure: CMS finalizes 2015 call letter for MA, Part D plans

Hub on Policy and Advocacy

Pharmacists can play an important role in improving quality measures that affect a plan’s CMS star rating. This gives pharmacists leverage when they negotiate contracts with plans. 

On April 7, CMS released the Final 2015 Advance Notice and Call Letter on changes to Medicare Advantage (MA) and Medicare Part D for 2015. Of importance to pharmacists, the final call letter maintained the weighting of the three Part D medication adherence measures at 3x—as opposed to the decrease to 1.5x as proposed in the draft call letter—for the 2015 star ratings. 

This year’s call letter contains information on the MA and Part D programs that plans need to take into consideration when preparing their 2015 bids. The call letter will be read in tandem with the Part D final rule, which has not yet been published.

Display measures are measures that CMS looks at and collects data on but that do not yet affect star ratings. In the final call letter, CMS deferred until the 2016 star ratings the display measure for the medication therapy management (MTM) program completion rate for comprehensive medication reviews (CMR). This is because the Part D proposed rule contained so many changes to MTM that CMS wanted the dust to settle for a year before those changes start affecting star ratings, according to APhA Associate Director of Health Policy Michael H Ghobrial, PharmD, JD.

CMS also took some steps on preferred networks. The agency has awarded a contract to study beneficiary access to preferred cost sharing, and the agency will take action against plans whose network of pharmacies offering preferred cost sharing appears to provide too little in the way of beneficiary access.

In March 7 comments on the draft call letter, APhA offered feedback to CMS on changes for measures for 2015, changes to measures, access to preferred cost sharing, and MTM. APhA thanked CMS for recognizing the value of pharmacists’ patient care services and pharmacist involvement in affecting many star ratings that advance plans’ quality.

Regarding the agency’s deferral of the CMR completion rate measure, the Association voiced strong support for the proposed expansion of MTM eligibility in the Part D proposed rule, and agreed with APhA member experts in pharmacy quality in supporting the delay until the final rule is in effect.