CMS pulled complaints from the 2028 Star Ratings. The plans that aced it lose the most off their measure averages.

Vlada

2026-10-22 · on LinkedIn ↗

CMS pulled complaints from the 2028 Star Ratings. The plans that aced it lose the most off their measure averages.

CMS just pulled the complaints measure from the 2028 Star Ratings. 43% of members in rated MA-PD contracts are in contracts that earned 5 stars on it, so the plans that aced it lose the most off their measure averages.

Today's CMS memo: Complaints about the Health/Drug Plan will not count in 2028 (2026 measurement year), a year before the final rule removes it for good. The reason is data quality: the new online provider complaint form gives providers discretion over which or how many beneficiaries to attach to a complaint, so complaint volume can't be compared accurately across plans.

Who aced it, member-weighted complaints stars: Kaiser 5.00, Elevance 4.40, CVS (Aetna) 4.30, UnitedHealth 4.25. Humana 3.70, Centene 3.24, Devoted 2.81.

What taking it out does to each plan's average measure star (before CMS's reward factor, CAI and rounding): Across all rated plans, it takes 0.015 off (0.018 with the other 2028 rule changes in). Kaiser, Elevance, CVS and UnitedHealth lose 0.02 to 0.03. Healthfirst, Lifetime (Excellus and CDPHP) and the Minnesota and Michigan Blues lose 0.03 to 0.05. Devoted gains 0.03. Humana edges up.

Small numbers, but Star Ratings round to the half star, so for a contract sitting near a line this can decide the bonus. Which contracts cross isn't knowable yet: CMS also re-scores its improvement measures, which count complaints, and it doesn't publish those scores. Plans whose complaint rates rose this year can win some of it back there.

Want to know how close your contract sits to its line? Every Star measure, cut point and the distance to the next half star is in our MCP: vladahealth.com/data-access

Source
CMS HPMS memo, 2028 Part C and D Star Ratings Complaints about the Health/Drug Plan Measure, October 21, 2026; CMS 2027 Part C and D Star Ratings data tables and Technical Notes (Tables 8 and 9); CMS monthly enrollment by contract, October 2026. Vlada recompute engine. Vlada analysis.
Measure
CMS HPMS memo, October 21, 2026 (Vanessa S. Duran, Director, Medicare Drug Benefit and C & D Data Group): the Complaints about the Health/Drug Plan measure will not be included in the 2028 Part C and D Star Ratings (2026 measurement year) due to data quality issues; the online provider complaint form gives providers discretion to determine which or how many beneficiaries to associate with complaints, which precludes an accurate comparison of complaint volume across plans. The CY2027 final rule already removes it from the 2029 Star Ratings. Data: CMS 2027 Star Ratings measure stars for all 505 rated MA-PD contracts with a complaints star; October 2026 enrollment (35,075,093 members). Members in contracts with 5 stars on Complaints about the Health Plan: 43% (0.4316). Member-weighted complaints star: all rated plans 4.24; Kaiser 5.00, Elevance 4.40, CVS (Aetna) 4.30, UnitedHealth 4.25, Humana 3.70, Centene 3.24, Devoted 2.81 (query 66126f94). Direct effect = the change in each contract's weighted average of measure stars (CMS weights, the Overall's measure set) when complaints comes out, member-weighted; before the reward factor, CAI, rounding and hold-harmless, and with the improvement measures at their published star. 2027 rules / 2028 rules (call-center and statin measures out, adherence at weight 1): all rated plans -0.0145 / -0.0183 (0.015 / 0.018 off the average). UnitedHealth -0.017 / -0.022 (complaints 4.25, 33% of members at 5 stars); Humana +0.005 / +0.004 (complaints 3.70, 7% of members at 5 stars); CVS (Aetna) -0.017 / -0.021 (complaints 4.30, 39% of members at 5 stars); Kaiser -0.023 / -0.030 (complaints 5.00, 100% of members at 5 stars); Elevance -0.023 / -0.029 (complaints 4.40, 57% of members at 5 stars); HCSC +0.002 / +0.000 (complaints 3.28, 12% of members at 5 stars); Centene -0.002 / -0.005 (complaints 3.24, 0% of members at 5 stars); BCBS Michigan -0.029 / -0.036 (complaints 5.00, 100% of members at 5 stars); Devoted +0.029 / +0.033 (complaints 2.81, 3% of members at 5 stars); SCAN -0.028 / -0.032 (complaints 4.86, 90% of members at 5 stars); Highmark -0.024 / -0.030 (complaints 4.66, 69% of members at 5 stars); MHH (MCS, GlobalHealth) -0.022 / -0.025 (complaints 5.00, 100% of members at 5 stars); Healthfirst -0.043 / -0.053 (complaints 4.99, 99% of members at 5 stars); BCBS Minnesota (Aware) -0.038 / -0.044 (complaints 5.00, 100% of members at 5 stars); Lifetime (Excellus, CDPHP) -0.039 / -0.048 (complaints 4.98, 99% of members at 5 stars). Rounded: Kaiser, Elevance, CVS and UnitedHealth lose 0.02 to 0.03; Healthfirst, Lifetime (Excellus, CDPHP), BCBS Minnesota and BCBS Michigan lose 0.03 to 0.05; Devoted gains 0.03; Humana gains 0.005. Not modeled, and the reason no contract-level star change is claimed: CMS's improvement measures (Health Plan and Drug Plan Quality Improvement, weight 5 each) are built from each contract's measure-level changes, including complaints, with CMS's significance tests; CMS publishes the stars but not the scores, so the re-scored improvement stars cannot be computed from public data. The independent audit found that improvement re-scoring can move a contract a full step either way (e.g., UnitedHealth H2001, whose complaints rate rose from 0.08 to 0.11 per 1,000, would gain on improvement). Parent names are CMS's parent organizations: MHH Healthcare (MCS Classicare, GlobalHealth); Lifetime Healthcare (Excellus, CDPHP); Aware Integrated (Blue Cross and Blue Shield of Minnesota, Blue Plus); BCBS Michigan (BCBSM, Blue Care Network).