HealthTeam Advantage Issues Public Comment on Centers for Medicare & Medicaid Services Rule

WASHINGTON, April 4 -- Deanna Homer, vice president of pharmacy and quality programs at HealthTeam Advantage, Greensboro, North Carolina, has issued a public comment on the Centers for Medicare and Medicaid Services' rule entitled "Revisions in Response to the COVID-19 Public Health Emergency CMS-1744-IFC Display". The comment was written and posted on April 2, 2020:

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Care N' Care Insurance Company of North Carolina ("CNC-NC"), Inc. d/b/a/ HealthTeam Advantage is a wholly-owned subsidiary of the Moses H. Cone Memorial Hospital Corporation. CNC-NC offers Medicare Advantage Preferred Provider Organization and a Health Maintenance Organization Chronic Special Needs Plan in the Piedmont Triad regional of North Carolina. CNC-NC began offering Medicare Advantage products in 2016 and currently has 15,786 members and has an overall rating of 4 Stars. The 4 Star rating is due in part to the strong and collaborative provider networkCone Health has built over many years.

CNC-NC realizes the significant impact that COVID-19 is having across in the nation and appreciates that Legislative changes being implemented for Star Ratings.

CNC-NC comments on the proposed Interim Rule.

1. On the last paragraph pg. 147 and on 148 - HEDIS data collection activities are currently underway and can be an administrative burden to physician offices, plans and auditors.

* CNC-NC began HEDIS chart chase activities the last week of February 2020. For most providers, CNC-NC has direct access into the electronic medical record (EMR), so no resources are required from the provider offices. For those providers where the EMR is not available, CNC-NC sent faxed requests for chart information. To date, CNC-NC received more than 80% of the records required for the Chart Chases. Our quality analysts work remotely uploading the data that has been received into our HEDIS tool.

* Not all HEDIS Star measures require collection from chart chases. There are many measures that can be completed with claims and supplemental data that has been collected year-round by our quality team. CNC-NC has worked diligently to put processes in place to improve these measures. As a result, our measure percentage and Star rating improved from a 3 to a 4 Star rating and would like to use these data in our calculations. These changes impact both the individual measure rating and the overall improvement calculation.

* CNC-NC disagrees that it is not possible to safely continue the HEDIS collection activities while complying with CDC recommendations as most of our collection is done by remotely connecting to the EMRs

* CNC-NC has collected most of the required data and results have been phenomenal. CNC-NC has 6 measures that are above the final numbers from last year. There are charts that still need to be loaded into our HEDIS tool and one more administrative refresh of data. For 5 of the HEDIS Star measures we are less than 50 charts from hitting a 5 Star and 2 are single digits away. These changes impact both the individual measure rating and the overall improvement calculation.

* CNC-NC requests that CMS allow plans to continue to report HEDIS data. CNC-NC also recommends a hybrid methodology where NCQA allows commercial and Medicaid plans - to report their audited HEDIS 2019 hybrid rate if it is better than their HEDIS 2020 hybrid rate as a result of low chart retrieval in a measure.

2. On the second paragraph pg. 148Consumer Assessment of Healthcare Providers and Systems (CAHPS) surveys.

* The timing of the interim rule comes after the 1st and 2nd round mailing of the surveys has already begun. Last year ~98% of our responses were received via mail and we completed educational outreach to members and providers about the importance of completing all surveys. By ending this process now, it tells members the survey is no longer important to the plan. CNC-NC would like to collect the mailing data, but not initiate the outbound telephonic collection.

* Health Outcomes Survey (HOS) does not impact the 2021 Star Ratings and CNC-NC supports delaying the collection to this summer.

3. b. Adjustments to the 2021 Star Ratings Methodology due to Lack of HEDIS and CAHPS Data.

* CNC-NC supports "Removing all of these measures would severely compromise the integrity of the Part C and D Star Ratings and would have significant impact on payment for MA organizations." CNC-NC disagrees that measure scores and stars do not fluctuate significantly year to year. CNC-NC has made significant strides and improved last year's overall star from a 3 to a 4. CNC-NC is on track to maintain a 4 Star with the improvements put in place past year.

* CNC-NC strongly requests CMS to allow plans to continue to report HEDIS data. Again, the plan supports the hybrid methodology where NCQA allows commercial and Medicaid plans - to report their audited HEDIS 2019 hybrid rate if it is better than their HEDIS 2020 hybrid rate as a result of low chart retrieval in a measure.

4. c. Use of 2020 Star Ratings to substitute for 2021 Star Ratings in the event of extraordinarily compromised CMS capabilities or systemic data issues.

* Rather than a review of measure-by-measure for the next several months, CNC-NC supports forgoing reporting of all 2021 Star data and carrying forward the 2020 plan performance. This would allow all plans to discontinue current activities and refocus on making the future better. This would eliminate the need for the results from data validation for the Part D Comprehensive Medication Review measure; results from the Timeliness Monitoring Audit that is currently underway for both the Part C and Part D appeal timeliness measures, the HEDIS audits currently underway, as well as the Call Center monitoring audits for the Part C and Part D measures.

Please contact me directly if I can provide further clarification.

Your consideration of this information is greatly appreciated.

Deanna Homer, Vice President of Pharmacy & Quality Programs

HealthTeam Advantage

7800 McCloud Road, Suite 100

Greensboro, North Carolina 27409

Direct: 336-790-4385

E-mail: [email protected]

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The rule can be viewed at: https://www.regulations.gov/document?D=CMS-2020-0032-0001

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