Response to 60-Day Public Comments

CMS Response to Public Comments Received for CMS-R-246
CMS received four comments related to CMS-R-246 (OMB control number 0938-0732) for the
Medicare Advantage, Medicare Part D, and Medicare Fee-For-Service Consumer Assessment of
Healthcare Providers and Systems (CAHPS) Survey.
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Comment: Two commenters were concerned the CAHPS questionnaire will not accurately
capture their members’ experiences with phone or video visits. They suggest that CMS
include “in-person, phone, or video” types of appointments in the survey instructions to
account for the increase in telehealth appointments during the COVID-19 public health
emergency. One of these commenters suggested specific question modifications to revise
references to specific sites of care and help ensure respondents consider telehealth.
Response: CMS agrees that the survey instructions should be modified to ask beneficiaries
to consider in-person, phone, and video visits; we have made that change in the instruments.
We will consider for the future whether any changes should be made to specific questions to
further account for virtual care. Any future changes will need to be tested and proposed
through rulemaking.

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Comment: One commenter supported the collection of information from Medicare
beneficiaries because it allows for a better understanding of how to best provide for the
insured and better deliver services to them.
Response: CMS appreciates this comment.

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Comment: One commenter expressed concern for how the 2021 survey will be used to score
plans for payment purposes as a result of the COVID-19 pandemic and suggested CMS use
the better of the 2021 or 2019 CAHPS surveys for the 2022 Star Ratings.
Response: Under the Part C and D Star Ratings extreme and uncontrollable circumstances
policy at §§ 422.166(i)(2) and 423.186(i)(2), contracts with at least 25 percent of their
service area in a FEMA-designated Individual Assistance area in 2020 will receive the higher
of their measure-level rating from the current and prior Star Ratings years for purposes of
calculating the 2022 Star Ratings. Since all contracts qualify for this extreme and
uncontrollable circumstances policy for the 2022 Star Ratings, contracts will receive the
higher of their measure-level ratings from 2021 Star Ratings (which use 2019 CAHPS
surveys) or 2022 Star Ratings (which use 2021 CAHPS surveys) for the applicable measures
following the rules described at 84 FR 15770–77.