CY2027 CMS Proposed Rule: Moving From Process to Impact

The Centers for Medicare & Medicaid Services (CMS) just released the Contract Year 2027 Proposed Rule (CMS-4212-P), and it represents one of the most meaningful shifts we’ve seen in the Medicare Advantage and Part D Star Ratings program in years.  

The short version:

  • 12 largely administrative and operational measures are slated for removal.
  • Clinical outcomes and patient experience measures will become more central.
  • Actual performance on member health and experience matters more than process checkboxes.

In other words, clinical quality is becoming the power metric.

For health plans, this is an important signal that future Stars success will depend on the ability to improve real-world outcomes, especially in areas like medication adherence, polypharmacy, and chronic disease management.

And that’s exactly where MedWatchers excels.

What CMS Is Proposing for Star Ratings

1. Removing 12 Measures – Mostly Admin, Process, and “Topped-Out” Performance

CMS proposes removing twelve measures from the Part C and D Star Ratings: seven operational/administrative, three process-of-care, and two patient experience measures.

Operational & Administrative measures to be removed:

  • Plan Makes Timely Decisions About Appeals (Part C)
  • Reviewing Appeals Decisions (Part C)
  • SNP Care Management (Part C)
  • Call Center – Foreign Language Interpreter & TTY Availability (Part C & D)
  • Complaints About the Health/Drug Plan (Part C & D)
  • Medicare Plan Finder (MPF) Price Accuracy (Part D)

Process & experience measures to be removed:

  • Diabetes Care – Eye Exam (Part C)
  • Statin Therapy for Patients with Cardiovascular Disease (Part C)
  • Members Choosing to Leave the Plan (Part C & D)
  • Customer Service (Part C)
  • Rating of Health Care Quality (Part C)

CMS’ rationale is consistent across these: performance is already very high with little variation, denominators can be small and volatile, and some measures are better suited for compliance monitoring or the display page rather than quality ratings.

Why this matters: once these are removed from the ratings, the remaining measures, particularly clinical and outcome measures, carry more relative weight in a contract’s summary and overall ratings. CMS is explicit that reducing operational and administrative measures will increase the relative influence of outcome measures in the final Star Ratings.

2. Adding a New Measure: Depression Screening and Follow-Up (DSF)

CMS proposes bringing Depression Screening and Follow-Up (DSF) (Part C) into the Star Ratings for 2029 (measurement year 2027).

  • DSF measures the share of eligible members who are screened for depression using a standardized tool and, if positive, receive follow-up care within 30 days.  
  • It aligns with U.S. Preventive Services Task Force recommendations and fills a gap: currently there’s no behavioral health–specific clinical measure in Star Ratings.  

CMS will start reporting DSF on the display page beginning with the 2026 Star Ratings, then move it into the Star Ratings measure set after at least two years on display, following standard policy.

3. HEI Reward Paused, Historical Reward Factor Stays

Previously, CMS finalized a Health Equity Index (HEI) reward (also known as EHO4all) to incentivize improved performance for dual-eligible, LIS, and disabled enrollees paired with removal of the historical reward factor starting in the 2027 Star Ratings.

In this new proposal, CMS would not move forward with the HEI reward and instead continue the historical reward factor beyond 2026, keeping the current reward structure in place while it explores broader Star simplification options.

The Big Shift: Impact Over Process

If you zoom out, CMS is doing three important things:

  1. Shrinking the measure set by cutting admin-heavy and “topped-out” measures.
  1. Centering Stars around clinical care, outcomes, and patient experience where performance still varies and improvement is needed.
  1. Maintaining the existing reward factor structure while asking for ideas to simplify the methodology going forward.

For plans, that translates to a very simple reality: The future of Stars is impact, not paperwork.

With administrative measures leaving the stage, contracts will be rated on how well they manage real member health issues, including:

  • Medication adherence
  • Polypharmacy and medication safety
  • Chronic disease management (e.g., diabetes, cardiovascular health, behavioral health)

Where MedWatchers Fits: Turning Whole-Person Data Into Stars-Critical Performance

In a previous NCQA post, we talked about care integration: connecting people, processes, and technology to support whole-person care.

That lens is even more important under the proposed Stars changes.

A care plan can look perfect in the EHR but still fails to treat the member properly: maybe they can’t read the instructions, can’t afford their meds, or don’t have a ride to their follow-up visit. On paper, the process box is checked. In reality, the outcome is at risk.

MedWatchers was built for this gap.

Our platform is designed to help plans and providers:

  • Pinpoint at-risk members earlier by tracking medical, behavioral, and social needs in real time.  
  • Eliminate care gaps through targeted medication reviews, polypharmacy management, and continuous medication monitoring.
  • Respect language and communication preferences so that outreach actually lands in preferred communication channels, such as digital-first messaging
  • Coordinate seamless handoffs between pharmacists and other care team members so patients don’t fall between silos.  

As CMS increases its focus in Stars on effective clinician–member follow-up, the priority is meaningful closure of the care loop rather than expanded documentation.

Omnichannel Outreach to Keep Members Engaged

You can’t improve adherence, depression follow-up, or chronic disease control if you can’t reach people.

That’s why we focus on omnichannel outreach: phone, text, email, mail, even in-person touchpoints when needed, so members can connect in a way that fits their daily lives and literacy levels.  

Done well, this kind of outreach moves the needle on Stars-critical metrics like adherence, patient safety, and follow-up after positive screens (including future measures like DSF).

How Plans Can Prepare Now

Even though this is a proposed rule, the direction is clear. Here are steps plans can take now:

  1. Re-balance your Stars strategy around clinical & outcome measures.
  1. Tighten medication management as a central Stars lever.
  1. Invest in integrated data and whole-person visibility.
  1. Scale omnichannel outreach and language-matching engagement.
  1. Treat Stars as a member-impact program, not a check-the-box program.

Final Thoughts

The CY2027 proposed rule marks a clear inflection point:

Stars is shifting from process to performance, from how well you document care to how well your members actually do.

At MedWatchers, we’re focused on helping our partners lead in that future by connecting the right people, processes, and technology to deliver measurable, clinical gains in the real world.

If you’d like to understand what these proposed changes could mean for your specific contracts, or how to modernize your Stars strategy around clinical impact, our team is ready to dig in with you.