The Stars roadmap just got a bit more crowded and, arguably, a bit more consequential.
Anyone working in or following Medicare Advantage (MA) knows this is not a simple moment for the program. We already have a sweeping proposed MA and Part D rule for 2027, an active transition to electronic measures (ECDS), and CMS’s longer term push toward a Universal Foundation across quality programs. All of that is happening at once.
Against that backdrop, it’s easy to overlook the quieter but critical details embedded in the annual Advance Notice. Much of the document is rate-focused (and yes, I still read that part), but buried in the text are the pieces that function as the operating manual for Stars: calendars, deadlines, measure additions and removals, weighting shifts, and implementation guidance that will shape plan performance for years. Generally speaking, Star changes need to be published in rules, but the notices and announcements serve as the implementation guide for plans.
Below is a focused walk-through of the Stars-related highlights from the proposed 2027 Advance Notice, which will be finalized in the April Final Announcement.
Deadlines/Calendar Reminders for Star Year (SY) 2027 and SY 2028
For Measure Year (MY) 2025 / SY 2027, plans should note:
- March 31, 2026 – Complaints Tracking Module (CTM) data review requests
- May 18, 2026 – Part D drug measure administrative data review requests
- June 30, 2026 – Part C appeals data review requests
For MY 2026 / SY 2028:
- March 31, 2027 – CTM data review requests
- May 18, 2027 – Part D drug measure administrative data review requests
One important reminder here: these review deadlines arrive before final PDE and appeals data are complete and before what many think of as the “official” closeout at the end of June. Practically speaking, plans need to be reviewing data early and aggressively, particularly for discrepancies that may not fully surface until after submission windows close.
Measure Additions, Removals and Changes for MY 2025 / SY 2027
CMS proposes six new or updated measures for SY 2027, including:
- New Measure: Colorectal Cancer Screening – Being respecified and treated as a new measure, with an expanded age band. Guardrails will not apply, and the impact at the half-Star cut point could be meaningful.
- New Measure: Care for Older Adults – Functional Status Assessment (COA-FS)
- New Measure: Concurrent Use of Opioids and Benzodiazepines (COB)
- New Measure: Polypharmacy: Use of Multiple Anticholinergic Medications in Older Adults (PolyACH)
- Changed Measure: Statin Use for Persons with Diabetes (SUPD) – Added a statin tolerance exclusion
- Changed Measure: Diabetes Care — Eye Exam (EED) – Removal of the chart review option
Three measures will be removed beginning in SY 2027:
- Care for Older Adults – Pain Assessment
- Medication Reconciliation Post-Discharge
- MTM Program Completion Rate for CMR (NOTE: with a planned return in SY 2029)
Weighting changes for SY 2027:
- Improving or Maintaining Physical Health (IMPH) moving from 1x to 3x weight
- Improving or Maintaining Mental Health (IMMH) moving from 1x to 3x weight
- Health Outcome Survey (HOS) moving from 1x to 3x weight
Other Notable SY 2027 Updates
- Part C Appeals: CMS will use Part C reporting data to validate the completeness of IRE data used in the appeals timeliness measures.
- CAI methodology: For the first two years after contract consolidation, LIS/Dual and Disabled percentages will be calculated using combined December enrollment across merged contracts.
- EHO4all: While still reflected in measure tables, the proposed rule would retroactively remove EHO4all for SY 2027 while retaining the Reward Factor.
Disasters in Play for SY 2027
CMS identifies two disasters affecting SY 2027:
- January 2025 Los Angeles Wildfires
- July 2025 Texas storms and flooding
The LA wildfires are notable in that they affect both SY 2026 and SY 2027 CAHPS results, with plans receiving the better of the two years. In some cases, this effectively pulls forward SY 2025 measure-level results.
Looking Ahead: SY 2028 and Beyond
Several forward-looking changes deserve attention:
- Statin Therapy for Patients with Cardiovascular Disease (SPC) is undergoing substantive changes and ECDS conversion, with proposals ranging from display-only status to full removal.
- Medication adherence measures will incorporate risk adjustment and temporarily drop to 1x weight.
- Call Center measures are proposed for elimination in SY 2028.
Beyond that, CMS and NCQA are signaling continued evolution for Readmissions, Transitions of Care, Diabetes Blood Sugar Control, and multiple display measures—many tied to an eventual shift to ECDS-only reporting by MY 2029.
A Word on Cut Points
Finally, CMS continues to explore simplifications to the Star Ratings methodology, including the possible use of percentile-based cut points instead of clustering for non-CAHPS measures. This could improve transparency and predictability but it also introduces the possibility that CMS more explicitly “sets” the distribution of Star outcomes.
What This Means for MA Plans
The Stars program is not just changing. It is layering change upon change. Plans that understand the Advance Notice offers the operational insights that light the path to a 4+ Star performance are the ones that are best positioned to succeed. This is no small task given the volume, complexity and nuance of how CMS administers Stars. At Lilac, we closely track all CMS communications, including the Advance Notice, to help plans quickly and efficiently translate Star program changes into aligned strategy and tactics.
This article is published in collaboration with The Healthcare Labyrinth. For a more detailed review of the 2027 Advanced Notice, check out the accompanying article on the HCL blog.
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Lilac’s Stars Management platform helps plans navigate these types of major changes to Stars. We have the data models and analytics to easily understand the strategic implications of Stars program changes and agentic AI tools to make a plan’s member engagement in support of Stars more efficient and impactful.
Reach out here to start a conversation with the Lilac team about how we can help your plan.