The Medicare Advantage (MA) Star Ratings program was already entering a period of significant change. CMS has finalized a major redesign for Star Year (SY) 2029 that reduces the number of measures, increases the emphasis on outcomes, and raises the stakes for sustained quality improvement.
Now, a federal court ruling in favor of Clover Health has introduced another layer of uncertainty.
While the legal process is far from over, the decision has already prompted CMS to recalculate ratings for certain contracts and could influence how quality is measured and rewarded in the future. More importantly, it has created a new challenge for Medicare Advantage organizations: planning for multiple potential versions of the Stars program at the same time.
For quality leaders, the question is no longer simply whether the ruling stands. The question is how to prepare for a future where the composition of the Stars program could continue to evolve.
Clover Health challenged its 2026 Medicare Advantage Star Ratings, arguing that CMS lacked statutory authority to include certain measures in the program and that some changes were implemented without following the formal rulemaking process required under federal law.
A federal court agreed with portions of Clover's argument and ordered CMS to recalculate Clover's Star Ratings. The ruling called into question approximately 20 measures currently included in the Stars program, many of which are tied to member experience, Part D performance, operational metrics, and improvement activities.
Following the decision, CMS recalculated Clover's ratings and instructed the organization to submit an alternative bid for the 2027 payment year.
While the ruling currently applies only to Clover, its broader implications could extend far beyond a single contract if the decision ultimately survives appeal.
The most significant development since the original ruling has been CMS's response.
Rather than limiting recalculations solely to Clover, CMS recalculated ratings for many Medicare Advantage contracts using a "better-of" methodology similar to the agency's approach following the Tukey litigation.
Under this approach, CMS compared a contract's original Star Rating against a recalculated rating that included fewer measures but totally consistent with the court ruling. Plans whose ratings improved received the higher score, while plans that would have been negatively impacted retained their original rating.
In other words, no organization was penalized by the recalculation.
This “hold harmless” or “better of” approach provides some short-term stability while the legal process continues. CMS has also indicated that these actions do not necessarily establish a precedent for future Star Years and continues to reserve the right to pursue appeals.
For plans, the message is clear: uncertainty remains, but CMS is actively working to minimize disruption while the issue is resolved.
Although much of the discussion has focused on legal arguments and court decisions, the more important issue for Medicare Advantage organizations is how the ruling could reshape quality measurement.
If the decision ultimately stands, the Stars program could become significantly more dependent on traditional clinical quality measures while placing less emphasis on other performance domains.
In the meantime, plans are wondering what will happen with 2027 Star Year ratings. That will be announced in October after Plan Preview.
Many of the measures potentially affected by the ruling fall outside traditional HEDIS measurement.
As a result, HEDIS clinical quality performance could account for a much larger share of a plan's overall Star Rating. Organizations with strong HEDIS programs may be better positioned under this scenario, while plans that have historically benefited from strong operational, survey or drug measure performance could face new challenges.
Perhaps the most notable implication involves Part D quality measurement.
Several medication adherence and other drug measures are among those affected by the ruling. If these measures were permanently removed, it would fundamentally alter how pharmacy quality contributes to Star Ratings.
However, plans should not interpret this as a signal that drug safety and medication adherence is becoming less important.
Drug safety and medication adherence remain closely linked to patient outcomes, avoidable utilization, and overall quality performance. Regardless of how the legal challenges unfold, CMS, policymakers, and healthcare organizations continue to recognize the importance of medication management and adherence improvement.
The court ruling raises questions about the future role of CAHPS and Health Outcomes Survey (HOS) measures. While the court seeming struck numerous CAHPS and HOS measures (at least temporarily), CMS’ recalculation put many of these back into the recalculation scenario.
Member experience has long been a critical component of Medicare Advantage quality measurement. While the weighting or structure of these measures could evolve, few industry observers expect member experience to disappear as a quality priority.
Organizations that pull back from CAHPS or HOS improvement efforts could find themselves at a disadvantage if those measures return through future rulemaking or legislative action.
Perhaps the most important lesson from the Clover ruling is that Medicare Advantage organizations can no longer afford to evaluate performance through a single lens.
Today, plans should be assessing performance across four lenses.
The first scenario assumes that appeals or legislative action ultimately preserve the program largely as it exists today for the next two Star years – 2027 and 2028.
Under this model, organizations should continue focusing on current measure performance, drug measures, member experience, and year-over-year improvement.
CMS has already finalized significant changes beginning with Star Year 2029.
The redesigned program reduces the overall number of measures, increases emphasis on outcomes, and creates a more targeted approach to quality measurement.
Because these changes have already been finalized, this remains the most predictable version of the future Stars program and should continue to serve as a primary planning framework.
If the ruling survives appeal and broader changes are implemented, the Stars program could become much more concentrated around HEDIS performance and a smaller set of quality measures. In Scenario 3, more CAHPS and HOS measures are included. In Scenario 4, the program would be very HEDIS focused.
While many experts believe CMS or Congress would ultimately act to preserve key elements of the current program, organizations should still understand how these last two scenarios would affect ratings, quality bonus payments, and operational priorities.
The ability to model performance across all four scenarios is becoming increasingly important for strategic planning.
The worst response to uncertainty is inaction.
Rather than redesigning quality programs around a court ruling that may still change, organizations should focus on capabilities that create value regardless of how the Stars program evolves.
The Star Year 2029 redesign remains the most concrete and actionable change currently facing Medicare Advantage plans.
Organizations should continue preparing for fewer measures, greater outcomes focus, and increased performance expectations.
Even amid uncertainty around Part D measurement, medication adherence and drug safety remains one of the strongest levers for improving both outcomes and quality performance.
Plans should continue investing in adherence outreach, pharmacy engagement, and medication management strategies.
Member experience continues to matter.
Whether through the current Stars program, future rulemaking, or broader quality initiatives, organizations that maintain strong member engagement and experience programs will remain better positioned for long-term success.
Regardless of which version of the Stars program ultimately emerges, plans will need the ability to:
Organizations with strong analytics and performance management capabilities will be better equipped to adapt as the regulatory landscape continues to evolve. And the brave new world of Stars will require efforts to reach more and more members to ensure the best rating possible. Using AI to analyze gaps for barriers and hone outreach strategies will be critical. AI co-piloting and orchestration would bring major efficiencies. AI-driven agents (text and voice) also drive reach very efficiently. These AI solutions are built right into MediSolv’s Stars Analytics platform.
CMS is expected to continue pursuing legal remedies, and additional appeals could delay a final resolution.
Congress could also become involved if policymakers determine that statutory changes are needed to preserve key elements of the Stars program.
For now, the most likely outcome is continued uncertainty as regulators, courts, and industry stakeholders work through the implications of the ruling.
The Clover Health ruling is one of the most significant Medicare Advantage Stars developments in recent years, not because it immediately changes how plans should manage quality, but because it introduces new uncertainty into an already evolving program.
The fundamentals of quality improvement remain unchanged.
Organizations should continue focusing on clinical performance, medication adherence, member experience, and data-driven quality improvement while preparing for multiple potential futures.
The plans that will be best positioned moving forward are not the ones waiting for certainty. They are the ones building the flexibility, analytics, and quality improvement capabilities needed to succeed regardless of how the Stars program ultimately evolves.
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