CMS CY 2027 Final Rule: Star Ratings Overhaul - What Compliance Teams Need to Know
Sevana Health Team
April 5, 2026
The CY 2027 Final Rule is out, and the Star Ratings changes are significant. CMS finalized removal of 11 measures from Star Ratings and finalized that the Health Equity Index (HEI) reward will not be implemented. This is a significant development for MA compliance and quality teams.
Source:
Everything below comes from the CY 2027 Final Rule (CMS-4208-F3 / CMS-4212-F), published in the Federal Register, Vol. 91, No. 65. The rule is effective June 1, 2026, with regulations applicable to coverage beginning January 1, 2027.
The Short Version
CMS proposed removing 12 measures. After public comment, they kept one (Diabetes Care–Eye Exam) and finalized the removal of the other 11. Their reasoning is straightforward: these measures have “topped out” (performance is consistently high across contracts with limited variation), or they're administrative and operational in nature rather than focused on clinical outcomes or patient experience.
Separately, CMS decided not to implement the Health Equity Index (HEI) reward, sometimes called “Excellent Health Outcomes for All.” Instead, the historical reward factor stays in the methodology. We'll get into what that means for ratings below.
Which Measures Are Going Away
The removals happen on two timelines. Three measures come out starting with the 2028 Star Ratings. The other eight come out starting with the 2029 Star Ratings (2027 measurement year).
Gone Starting 2028
- •Call Center: Foreign Language Interpreter and TTY Availability (Part C and Part D). Performance was 94% on the Part C side and 94 to 97% on Part D in the 2025 Star Ratings, with limited variation across contracts
- •Statin Therapy for Patients with Cardiovascular Disease (Part C). NCQA made substantive specification changes for the 2026 measurement year, which already triggered removal to the display page under § 422.164(d)(2). CMS couldn't continue using the legacy version due to the nature of the changes.
Gone Starting 2029
- •Plan Makes Timely Decisions about Appeals (Part C). Average performance went from 90% to 96% between the 2015 and 2025 Star Ratings.
- •Reviewing Appeals Decisions (Part C). Went from 88% to 95% over the same period.
- •SNP Care Management (Part C). This one only measures whether an HRA was completed, not whether the enrollee actually received care based on it. CMS wants to focus on whether care was delivered, not just whether a box was checked.
- •Complaints about the Health/Drug Plan (Part C and Part D). Complaint volume has dropped significantly since this measure was introduced. In the 2025 Star Ratings, average performance was 0.23% for MA-PD and 0.04% for PDP (lower is better).
- •MPF Price Accuracy (Part D). Average scores were 98 for MA-PD and 97 for PDP. Not much to differentiate.
- •Members Choosing to Leave the Plan (Part C and Part D). People leave plans for all kinds of reasons (cost, network changes, moving), so the disenrollment rate is hard to read as a quality signal.
- •Customer Service (Part C) and Rating of Health Care Quality (Part C). Less variation across contracts compared to other patient experience measures. The broader Rating of Health Plan measure stays in Star Ratings and covers similar ground.
The One They Kept: Diabetes Care–Eye Exam
This is the interesting one. CMS proposed removing it, but commenters pushed back hard. The argument: diabetic retinopathy is a leading cause of preventable blindness, and this is the only vision-focused measure in Star Ratings. CMS agreed. In the final rule, they said keeping it will “help maintain plan accountability, support access to preventive screening, and encourage care coordination and innovation in screening approaches, particularly for high-risk and underserved populations.” It stays.
HEI Reward: Not Moving Forward
The Health Equity Index reward was codified at §§ 422.166(f)(3) and 423.186(f)(3) but never actually went live. It was designed to incentivize plans to improve outcomes for underserved populations. CMS finalized that the HEI reward will not be implemented. The historical reward factor at §§ 422.166(f)(1) and 423.186(f)(1) stays in place instead. This takes effect with the 2027 Star Ratings.
So What Happens to Ratings?
CMS ran simulations using 2025 Star Ratings data. Here's the combined impact of the measure removals, the HEI decision, and keeping the historical reward factor:
63%
of contracts: no change
13%
of contracts: up half a star
24%
of contracts: down half a star
On Quality Bonus Payments: 4% of contracts would gain QBP eligibility, 3% would lose it.
The math is a bit of a push-and-pull. Removing the measures alone would generally pull ratings down, because most plans scored well on them. But keeping the historical reward factor and not implementing the HEI pushes ratings back up. The net result is that most plans stay put, but about one in four takes a half-star hit.
Because fewer measures now drive the overall score, performance volatility increases. That raises the stakes for plans that are borderline on QBP eligibility or rely on stable rebate assumptions. A half-star swing that used to be cushioned by high-performing administrative measures is now more exposed.
It's Not Only Subtraction
Worth noting: CMS is also adding a new Part C measure, Depression Screening and Follow-Up, for the 2027 measurement year (impacting the 2029 Star Ratings). So the measure set is not just shrinking. CMS is refocusing it toward clinical outcomes and areas where performance still varies meaningfully across contracts.
Removed from Ratings, Not from Oversight
This is the part that matters most for compliance teams. CMS made a point of saying this repeatedly in the rule: taking a measure out of Star Ratings does not mean they stop watching.
Display page reporting continues
Every removed measure will still be publicly reported on the CMS display page (separate from Medicare Plan Finder). The data is still collected, still published, still visible.
Compliance actions are still on the table
CMS will keep monitoring through existing oversight activities. If a plan falls out of compliance on its contract terms, CMS can still issue warning letters and corrective action plan (CAP) requests under 42 CFR 422.504(m)(3), and those get publicly posted.
Too many compliance actions? Contract risk.
CMS can deny applications for new contracts or service area expansions under 42 CFR 422.502(b)(1) if an organization has a pattern of compliance issues.
Appeals get specific attention
CMS specifically noted they'll continue to monitor appeals performance and take compliance actions based on appeals data. The CAHPS survey measures also still capture access-to-care issues from the enrollee perspective.
What This Means in Practice
Every remaining measure now carries more weight
Fewer measures in the calculation means each one has a bigger impact on the overall rating. Several commenters flagged that CAHPS and HOS survey measures would take on a larger share. CMS acknowledged the shift but stood by the surveys as “standardized, validated instruments” with “multiple methodological safeguards.”
Don't let removed measures slip
The QBP incentive for appeals timeliness, complaints, and call center performance is going away. The enforcement risk is not. Plans that let these areas degrade are still looking at CAPs, warning letters, and potential contract action. The financial incentive changed, but the regulatory obligation didn't.
Run your own projections
CMS's simulation showed 24% of contracts losing a half star. If your plan has historically benefited from high scores on the removed measures, you should model what happens when those scores no longer count. A half-star drop can ripple into QBP eligibility, rebate funding, and supplemental benefit design.
More removals are coming
The rule states CMS “is also considering removing additional measures in the future as we continue to simplify and refocus the program.” Future removals will require rulemaking, so there will be a comment period. But the direction is clear: the measure set is shrinking.
Key Dates
- •June 1, 2026: Rule takes effect
- •2027 Star Ratings: HEI reward will not be implemented; historical reward factor stays; measure removal process clarifications take effect
- •2028 Star Ratings: Call Center (Part C and D) and Statin Therapy (Part C) removed
- •2029 Star Ratings: The remaining 8 measures removed (2027 measurement year data)
For plans, the takeaway is straightforward: removal from Star Ratings does not mean removal from scrutiny. The operational disciplines behind appeals, complaints, and data integrity still matter. That is where strong compliance infrastructure matters most.
How Sevana Health Can Help
Sevana Health helps MA plans stay ahead of CMS oversight, from universe file validation to compliance work plan tracking. If the operational compliance work is shifting from quality incentives to direct enforcement, the tools you use to manage it should be built for that reality.