Cut through the noise, find the signal: Intelligence for serious healthcare leaders
How CMS grades MA plans, what each measure is worth, and where the money moves.
CMS uses a hierarchical clustering algorithm that analyzes the distribution of all contracts’ scores on a measure and identifies natural groupings. The algorithm creates four cut points that divide contracts into five clusters, each corresponding to a star level (1 through 5). The advantage: cut points reflect actual performance distributions rather than arbitrary thresholds. The risk: small shifts in the distribution can cause large rating changes.
Survey-based measures use a different method: relative distribution with significance testing. CMS calculates national averages, then tests whether each contract’s score is statistically significantly above or below the average to assign ratings. This method is more stable but less sensitive to genuine improvement.
| Year | Change | Impact |
|---|---|---|
| 2016 | Removed predetermined thresholds | Eliminated fixed 4-star thresholds. All ratings now determined by relative performance via hierarchical clustering. |
| 2022 | Mean resampling | Added resampling step within clustering to reduce sensitivity to outliers. More stable cut points year-over-year. |
| 2022 | Guardrails | Non-CAHPS cut points limited to max 5 percentage point change year-over-year, preventing wild rating swings. |
| 2024 | Tukey outlier deletion | Extreme outliers removed before clustering. Cut points shifted upward, making higher ratings harder to achieve. Subject of lawsuits. |
| 2026 | 60% FEMA rule removed | Contracts with 60%+ enrollees in disaster areas no longer exempt from disaster adjustments. |
| Source | What it is | How it’s collected | Measures |
|---|---|---|---|
| HEDIS | Healthcare Effectiveness Data & Information Set. Clinical quality measures defined by NCQA. | Plans submit data annually; NCQA audits. | Screenings, chronic disease mgmt, medication, follow-up measures |
| CAHPS | Consumer Assessment of Healthcare Providers & Systems. Member satisfaction surveys. | CMS-contracted vendors survey members Mar–May yearly. | Patient experience, access, customer service, plan ratings |
| CMS Admin | Claims, enrollment, complaints (CTM), appeals, disenrollment data. | Continuous collection from CMS systems. | Appeals timeliness, complaint rates, member retention, access |
| HOS | Health Outcomes Survey. Longitudinal survey of physical/mental health status. | Baseline at enrollment, follow-up 2 years later. | Improving/Maintaining Physical Health, Mental Health |
| PDE / IRE | Prescription Drug Event data and Independent Review Entity data. | Drug claims records + appeals data. | Medication adherence, drug pricing, drug safety |
| PQA | Pharmacy Quality Alliance. Drug safety and adherence measure specifications. | Calculated from PDE data using PQA specifications. | Adherence (diabetes, hypertension, cholesterol), statin use, high-risk meds |