The Medicare Advantage (MA) Star Ratings program has served as the primary quality measurement mechanism for MA since 2012. It determines which plans earn a Quality Bonus Payment (QBP) and how much rebate funding they have available to build competitive supplemental benefit offerings. Over the past several years, however, the program has grown increasingly complex, incorporating dozens of measures covering clinical outcomes, patient experience, and administrative performance. Each measure is scored individually and can move a contract across a bonus threshold. Capstone believes the Centers for Medicare & Medicaid Services (CMS) itself has become increasingly uncomfortable with the level of complexity of the Star Ratings program. The agency’s own conduct is more telling of what lies ahead for MA quality measurement than the Clover Health ruling, which has dominated recent industry discussions.
In May 2026, a federal judge ruled that CMS had improperly included 20 measures in calculating Star Ratings: 10 on the procedural basis of failing to abide by proper notice-and-comment rulemaking, and 10 on the substantive basis of relying on data sources outside of the agency’s statutory authority. The court ordered CMS to recalculate Clover’s Star Ratings, resulting in a 1-Star increase for the insurer after the disputed measures were removed. As a result of the ruling, CMS is conducting a recalculation of every contract’s Star Rating score, though only contracts with higher scores will be impacted, while others are held harmless.
More notable than any single ruling, in Capstone’s view, is what CMS has been doing in the background for years with far less attention. The agency routinely adds and removes individual measures in annual rulemaking cycles and adjusts the weight that each measure or measure category carries. The clearest recent example is the CY27 Policy and Technical Changes Rule, which finalized the deletion of 11 measures from the Star Ratings program, to be phased out between 2028 and 2029.
The Universal Foundation also points in this direction. First proposed in 2023 under the Biden administration and still supported by the Trump administration, the Universal Foundation is a set of quality measures that strongly emphasizes clinical outcomes and patient experience, and centered on Healthcare Effectiveness Data and Information Set (HEDIS) and Consumer Assessment of Healthcare Providers and Systems (CAHPS) data. Capstone believes this consolidation of measures is directionally where CMS aims to take the Star Ratings program in the coming years, and we anticipate the program could have as few as 10-15 measures in the next 5-10 years.
Additional reforms could manifest in a few key ways. The most likely is continued streamlining of measures through annual CMS rulemaking, which requires no legislative authorization or intervention by the Center for Medicare & Medicaid Innovation (CMMI). Alternatively, though slower-moving, Congress presents another path. Introduced in July 2026, the Saving MEDICARE Act proposes a complete sunset of the QBP program in 2028. Capstone views this bill as highly unlikely to advance, given its sponsor is retiring this year, at a moment when Congress has limited capacity to move Medicare Advantage legislation broadly. While it enjoys support from a small coalition of liberal Democratic House members, we do not anticipate this bill will earn broader support. This bill’s significance lies not in its odds of passage, but rather in what it signals. Historically, Medicare Advantage reforms in Congress have targeted other key elements of the program such as risk adjustment and utilization management, making this inclusion a noteworthy development and a signal that Congress may continue to turn its attention to Star Ratings.
CMMI presents another discrete vector for policy change, and Capstone believes it is more likely than Congress to produce near-term reform. The core mechanics of the QBP program are fixed by statute. Ordinary rulemaking can adjust measures and weights, but cannot rewrite them. CMMI’s waiver authority is different, letting CMS test alternative payment and quality structures within a defined population without waiting on Congress. Wholesale elimination of Star Ratings is unlikely, given the political cost of an administration appearing to abandon quality measurement. Possibilities that CMS could test, but has not yet proposed, include shifting quality reporting away from the contract level. Moving up to the parent organization level would favor larger, multi-contract payors that can average performance across more contracts; moving down to the plan level would cut the other way, surfacing weak plans that a strong contract average currently hides. A third option would be replacing today’s bonus cliff with a graduated payout. CMMI has these options available under its existing authority, but has not yet operationalized them.
The most immediate signal would be to track what CMS does in forthcoming rulemaking cycles, and whether CMMI develops a quality-focused model before the second Trump administration ends. Across every channel, the direction of travel is the same: pushing quality into the provider office, toward measures that capture actual clinical outcomes and away from check-the-box measures that have defined the Star Ratings program’s complexity to date.
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