Vlada · Research · 2026-10-22 · derived
CMS pulled complaints from the 2028 Star Ratings. The plans that aced it lose the most off their measure averages.
CMS's October 21, 2026 memo drops the Complaints about the Health/Drug Plan measure from the 2028 Star Ratings. Who would that help and hurt: if the measure came out of this year's (2027) Overall ratings, which contracts and parent companies move?
| Medicare Advantage Overall Star Ratings without the complaints measure | Overall star |
|---|---|
| All rated plansdirect effect, 2027 rules | -0.02 |
| Kaisercomplaints star | 5 |
| Devotedcomplaints star | 2.81 |
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). · 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. · 3 rows
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- Direct effect only: the change in each contract's weighted average when the complaints measure leaves. It is not a new Star Rating: the reward factor, CAI, half-star rounding and the hold-harmless all come after it.
- CMS's improvement measures also count complaints. CMS will re-score them without it, and it publishes the improvement stars but not the scores or significance tests, so their change cannot be computed from public data. Plans whose complaint rates rose this year can gain back on improvement and plans whose rates fell can lose more, where the change passes CMS's significance test; CMS also re-draws the improvement cut points.
- Both columns use 2027 measure stars. The 2028 column applies the CY2027 final rule's 2028 measure changes (two call-center measures and statin therapy out, the three adherence measures at weight 1) to those stars; 2028 itself uses 2026 data and new cut points.
- Members are October 2026 enrollment by contract, including employer group plans.
- Overall measure set; stand-alone drug plans also lose the Part D complaints measure and are not shown.
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