NCQA Medicare Advantage RFI Comments

NCQA urged CMS to add behavioral measures to the Medicare Advantage Star Ratings and remove the benchmark cap that prevents some high quality plans from getting bonuses they have earned.

April 24, 2017

Seema Verma, Administrator
Center for Medicare & Medicaid Services
200 Independence Ave. S.W.
Washington, DC 20201

Thank you for the opportunity to respond to your request for information on potential ways to improve Medicare Advantage. The National Committee for Quality Assurance strongly supports Medicare Advantage and its Star Ratings pay-for-performance system that is improving quality and attracting enrollees to the best plans as intended.

Our comments focus on two essential steps for strengthening the Star Ratings system:

  1. Addition of strong behavioral and mental health measures to the Star Ratings; and
  2. Eliminating the benchmark cap that prevents high-quality plans from receiving bonuses and higher rebates payments that they have earned to attract more enrollees.


Medicare Advantage plans must focus heavily on improving aspects of care measured in the Star Ratings to earn the bonuses and rebates that they need to stay competitive and attract enrollees with better benefits and/or lower costs. This pay-for-performance system increased the percentage of highly-rated 4-5 Star plans from 31% in 2010 to 49% in 2017. The percentage of beneficiaries enrolled in highly-rated plans rose even more, from 31% in 2012 to 68% in 2017.

Behavioral/Mental Health Measures

However, the Star Ratings system lacks strong behavioral health measures and we are thus seeing little progress on this critical facet of care. Behavioral and mental health conditions are substantially undertreated and strongly associated with increased spending on physical health care services. Many behavioral and mental health treatments also have significant side effects that require careful monitoring and often further treatment. There also is often little if any of the coordination between behavioral and other health care providers, which is essential for optimal care.

Adding behavioral and mental health measures to the Star Ratings will make improving behavioral and mental health care a priority in Medicare Advantage. We therefore strongly urge you to include more behavioral and mental health measures in the Star Ratings. Appendix A includes a list of behavioral and mental health measures that NCQA has or is developing. We would be happy to work with you and other stakeholders to determine the most appropriate of these and other mental/behavioral health measures for inclusion in the Star Ratings.

Remove the Medicare Advantage Benchmark Cap

The Star Ratings’ impact also is being limited because of an Affordable Care Act provision that caps at pre-ACA amount the county-level benchmarks against which Medicare Advantage plans bid. This is preventing many high-performing plans from getting Star Rating payments they need to attract enrollees to high quality care aa Congress intended. We therefore urge you to work eliminate this unfortunate policy through either administrative action or by working with Congress to change the law.

Thank you again for the opportunity to respond to the RFI. If you have any questions please contact Paul Cotton, Director of Federal Affairs, at (202) 955-5162 or



Frank Micciche
Vice President for Public Policy & Communications

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