By James Gutman - January 6, 2012

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Whatever else Medicare Advantage plans think about CMS, they will have to give the agency credit for one thing — being increasingly transparent about its regulatory initiatives. Just as it did in the past two years with scoring criteria for MA plans' Quality Improvement Projects and Chronic Care Improvement Programs, CMS late last month laid out what it is planning to do on star ratings for 2013 and beyond. And the reason observers say there are no "bombshells" in the contemplated stars changes is precisely because the potential new star measures and retirement of old measures represent just a continuation of what CMS had been saying before about such aspects as putting more emphasis on outcomes.

This was not always the case in the past two years. MA consultants still recoil in horror when they think of what happened on the 2011 bids that MA plans submitted in June 2010. As plan after plan was told to make rush changes in their bids because they did not meet criteria that CMS had not disclosed before the bids were due, their executives and consultants steamed about not being told in advance about the formulas CMS would be using to evaluate the bids. But for the bids MA plans had to submit for 2012 by June 2011, CMS did furnish in advance the specific standards for evaluating whether bids would be suitable, and the process from all accounts went much smoother.

It appears that the Dec. 20 memo on star-ratings changes follows the same mold. The unprecedented amount of advance notice covers not only likely new measures for star ratings, complete with the methodology that would be used for them, but also star measures that CMS is considering "retiring." The agency even gave considerable details on measures it was considering for the future and that it is still up in the air about.

Is this as much progress as it seems? Or does CMS still need to go a lot further before earning kudos for being transparent?