Fewer Star Ratings Measures, Higher Stakes for Your Call Center

CMS just made its Star Ratings math less forgiving, and the change lands squarely on the member service line. The Contract Year 2027 Final Rule, issued in April 2026, removes 11 measures from the Medicare Advantage and Part D Star Ratings, most of them administrative or process measures that CMS said no longer meaningfully distinguished one plan from another.¹ Removing them does not simply shrink the scorecard. It reweights it. With fewer measures in the total, CMS has tilted relative weight toward the survey based and clinical outcome measures that remain, and several of the survey measures that gained ground are shaped directly on member calls.²

For a Medicare Advantage plan, that raises the stakes on a part of the operation many still treat as a cost center. In a smaller measure set, a weak call center is no longer a contained quality problem. It is a direct drag on the overall rating and the quality bonus payment that depends on it.

The measure set just got smaller

Some context on where ratings sit. The 2026 enrollment weighted average Star Rating for Medicare Advantage plans with drug coverage was 3.98, and only about 40 percent of MA contracts earned four stars or higher, the threshold that triggers a quality bonus payment.³ Most plans are already sitting below the line that funds richer benefits.

Into that tight environment, the Contract Year 2027 rule removes 11 measures and tilts relative weight toward the survey based and clinical outcome measures that remain.⁴ Patient experience and access measures already had their weight cut from four times to two times for the 2026 ratings, so member experience carries less raw weight than it did a few years ago.⁵ What the removals change is the denominator. With the low differentiation measures gone, the surviving CAHPS experience measures are a larger share of a smaller set. Clinical HEDIS measures gain the most, but they move slowly. Among the measures a plan can influence quickly through daily operations, the CAHPS experience measures are the most reachable, and the call center shapes several of them.

Several of the survivors are decided on the phone

The experience measures CMS kept lean heavily on what members actually go through, and much of that happens on a call. Surviving CAHPS composites such as customer service, getting needed care, getting appointments and care quickly, and overall rating of the plan are shaped directly by how member calls go. When a member cannot get a question resolved, is transferred repeatedly, or feels unheard, that experience surfaces later as a lower survey score.

There is a sharper point in the timing. Among the measures CMS removed were the ones that used to grade call center and complaint handling directly, including the appeals timeliness, plan complaints, and call center interpreter measures. The call center lost its own dedicated scorecard, yet the experience it drives still flows into the CAHPS survey measures that remain. The rating exposure did not go away. It moved into measures where a sampling based QA program cannot tell a plan why a score moved.

What this looks like in practice: a plan's customer service composite has been flat for two years. Leadership assumes the scripts and training are fine because the quarterly QA sample looks clean. The sample, a few hundred manually scored calls, never surfaces the systemic issue, a recurring transfer loop on benefit questions, because it lives in calls that were never selected. The composite stays flat, and in a smaller measure set that flat score costs more than it used to.

Why sampling is now a ratings risk, not just a quality gap

Traditional call center QA reviews a small manual sample, historically a few percent of calls, and scores it well after the interaction. That model was always a blind spot. In a concentrated Star Ratings environment, it becomes a financial one.

When a plan reviews less than 5 percent of its member calls, it is inferring the experience behind measures that now move its rating and its bonus payment from a fraction of the evidence. Non-English calls are rarely sampled at all, which means the experience of entire language groups goes effectively unmeasured, even as those calls feed the same composites. A sample can tell a plan that a composite is stuck. Only the full population of calls can tell it why. The contrast between the two models is direct.

What to look for in a member experience solution

Improving the experience measures that now carry more weight starts with actually seeing them. When evaluating how to monitor and improve member calls, plans should look for:

• Evaluation of every member call rather than a sample, so systemic issues surface instead of hiding in unselected calls

• Scoring tied to the experience measures that drive ratings, including customer service quality and complaint drivers

• Translation and scoring of calls in every language, so no member group goes unmeasured

• Root cause visibility that explains why a composite is stuck, not just that it is

• Intelligence the plan owns and controls, rather than quality metrics self reported by a vendor

Claro by Mizzeto was built to give plans that full view. Its Member Sentiment & At-Risk Identification and Agent Empathy & Communication scoring evaluate 100 percent of member calls in any language, turning the experience behind CAHPS composites into something a plan can measure and improve rather than infer.

The bottom line

The Contract Year 2027 rule did not lower the bar for member experience. By removing the measures plans could coast on, it left the surviving experience measures carrying more of what a plan can actually influence, with no dedicated call center scorecard to flag trouble early. In a concentrated Star Ratings set, a member service operation measured by sampling is a rating left partly to chance. Plans that can see every call can find and fix what is holding a composite down, while plans reviewing a small sample keep guessing. To see how full call scoring maps to the Star Ratings measures that now carry the most weight, send us a sample of your calls and we will return scored transcripts before you commit to anything.

References

1. Crowell & Moring LLP, CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors. https://www.crowell.com/en/insights/client-alerts/cms-finalizes-cy-2027-medicare-advantage-and-part-d-rule-key-implications-for-plan-sponsors

2. Becker's Payer Issues, CMS pitches star ratings reform in 2027 Medicare Advantage rule: 7 notes. https://www.beckerspayer.com/payer/medicare-advantage/cms-pitches-star-ratings-reform-in-2027-medicare-advantage-proposed-rule-7-notes/

3. Cohere Health, CMS Star Ratings 2027 Final Rule: Health Plan Impacts (citing the CMS 2026 MA and Part D Star Ratings Fact Sheet). https://www.coherehealth.com/blog/cms-star-ratings-2027-final-rule-health-plans

4. CMS, Contract Year 2027 Medicare Advantage and Part D Final Rule fact sheet (April 2, 2026). https://www.cms.gov/newsroom/fact-sheets/contract-year-2027-medicare-advantage-part-d-final-rule

5. AJMC, The Stars Have Realigned (Again): What Medicare Advantage Plans Need to Know. https://www.ajmc.com/view/contributor-the-stars-have-re-aligned-again-what-medicare-advantage-plans-need-to-know

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The fallout from this year's premium shock did not wait for open enrollment. When the enhanced premium tax credits expired at the end of 2025, the price of 2026 coverage moved for almost everyone who buys it on the individual market, and it moved sharply. Average premium payments for subsidized Marketplace enrollees more than doubled heading into 2026¹, and effectuated enrollment is on track to fall from 22.3 million to roughly 17.5 million².

For a Marketplace plan, that is not an abstract policy shift. It is a wave of confused, price sensitive members calling right now, mid plan year, to ask why their bill changed, whether they still qualify for help, and whether a cheaper plan exists. Those calls are happening months before the next open enrollment window even opens, and the decision to stay or leave is being made on them well ahead of any renewal file. Marketplace member retention is being decided on the member service line today, and most plans are barely listening to it.

The 2026 reset changed who is on the phone

The expiration of the enhanced tax credits did more than raise prices. It changed the mix of people calling. A disproportionate share of the enrollment drop, about 27 percent, came from households just above the old subsidy cliff, even though that group made up only 3 percent of plan selections the year before². These are members who lost eligibility for help entirely and are now weighing coverage on price alone.

The result is higher call volume made up of harder calls. Billing questions, subsidy confusion, and plan comparison requests are exactly the interactions that resolve least often on the first attempt. And first call resolution is where this problem turns expensive: SQM Group benchmarks put first call resolution for complaint calls at 47 percent, the lowest of any call type and far below the healthcare insurance average³. The same research shows that in a given year, roughly 40 percent of customers who do not get their issue resolved on the first call defect to another company⁴. A price shocked Marketplace member whose billing question is transferred twice and never resolved is not a service statistic. That member is a renewal the plan is about to lose.

Churn shows up in the call before it shows up in the data

Retention data is a lagging indicator. By the time a member appears in a disenrollment report, the decision was made and the window to intervene has closed. The signal that predicts that outcome is audible much earlier, in the tone and content of the call itself.

What this looks like in practice: a member calls in October asking why the subsidy that covered most of the premium shrank. The agent explains the tax credit change, cannot fully resolve the affordability concern, and the call ends. Nothing flags the member as at risk. No follow up is triggered. In January the member is gone, and the plan learns about it from a report rather than from the call that predicted it.

Why sampling misses the members who matter most

Most plans still evaluate member calls the way they did a decade ago, by pulling a small manual sample and scoring it after the fact. When a plan reviews less than 5 percent of its member calls, the leaving decision almost always forms inside the 95 percent no one listens to. The signals that predict churn, the second unresolved call, the audible frustration, the mention of a competitor's premium, sit in the calls that were never selected.

The gap is widest exactly where the 2026 population is most exposed. Non-English calls are rarely part of a manual sample at all, yet language access is where affordability confusion compounds fastest. A sampling model does not just miss volume. It systematically misses the members whose experience is deteriorating and who are most likely to leave.

What to look for in a member call intelligence approach

The problem is not that plans lack member data. It is that the most predictive data, what members actually say when they call, is captured and then discarded. When evaluating how to close that gap, plans should look for:

• Coverage of every member call, not a sample, so at-risk members are identified rather than missed by chance

• Sentiment and risk detection that surfaces the members most likely to disenroll while there is still time to act

• Translation and scoring of calls in every language your membership actually calls in, so non-English members are not the least understood

• Transparency the plan controls, with the logic and the intelligence owned by the plan rather than a vendor

• Signal that reaches retention and enrollment teams quickly enough to intervene before renewal, not after

Claro by Mizzeto was built for this. Member Experience Insights is one of four capability areas within Claro, and it is the one focused specifically on this problem: identifying at-risk members before they disenroll, using the actual content and tone of their calls rather than a survey that arrives months later. It reviews 100 percent of member calls, scores sentiment and risk across every language a plan's membership calls in, and surfaces the members most likely to leave in time for retention teams to act, so outreach can happen before open enrollment closes rather than after the member is already gone.

The bottom line

The 2026 subsidy reset handed Marketplace plans a harder, more price sensitive population and a narrower margin for error. Retention this year will not be won by surveys that arrive after the decision or reports that confirm a loss already booked. It will be won on the call, in the moment a member is deciding whether the plan is worth the new price. Plans that can hear every one of those calls will keep members that sampling based plans never knew were leaving.

To see how full call member intelligence identifies at-risk Marketplace members before they disenroll, send us a sample of your calls and we will return scored transcripts before you commit to anything.

References

1. KFF. Analysis of premium payment increases for subsidized Marketplace enrollees following the expiration of enhanced premium tax credits, 2026. www.kff.org

2. Congressional Budget Office. Projected effects of the expiration of enhanced premium tax credits on Marketplace enrollment, 2026, including subsidy cliff impact by income band. www.cbo.gov

3. SQM Group. First call resolution benchmarks by call type, healthcare and insurance industry comparison. www.sqmgroup.com

4. SQM Group. Customer defection rates following unresolved first-call issues. www.sqmgroup.com

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In most years, Medicare Advantage disenrollment is a defensive problem: a plan keeps the members it has, and the losses are gradual. 2026 broke that pattern. A wave of plan exits pushed roughly 2.9 million Medicare Advantage members, about 10 percent of enrollees, out of plans that stopped serving their counties, a nearly tenfold jump from the 1 percent average that held from 2018 through 2024.¹ The market filled with switchers, and every plan is now fighting on two fronts, defending the members it has and competing for a large pool of switchers. The same thing decides both: whether the plan is easy to be a member of.

The same failure now costs a plan twice

Forced disenrollment, the county exits that drove the 2026 spike, is not a service problem, and no plan can prevent it. But everything the disruption set in motion afterward is within a plan's control. A market this unsettled taxes a weak member experience twice, once as the plan loses its own members and again as it fails to keep the switchers it wins. A new member arrives with no goodwill in reserve. A tenured member might forgive a bad call after ten good years; a member of ten days simply shops again.

Members leave for reasons a plan can see coming

On both fronts, the reasons are documented, and they are not mainly about price. In the Medicare Current Beneficiary Survey, the strongest predictors of leaving were difficulty accessing care, which raised the odds by about a third, and low plan generosity, by roughly half; cost alone was not significant once the other factors were accounted for.² CMS confirms it in its own monthly Disenrollment Reasons Survey,³ where close to a fifth of disenrollees cite problems getting services covered and roughly one in eight cite customer service.⁴ Those are the substance of member service calls.

The decision is usually audible before it is final

An honest caveat first: access and benefit design, the largest drivers, are not call center problems in origin, and listening does not widen a narrow network. What it does is surface the trouble first. Members rarely leave over a benefit design in the abstract; they phone to ask why a service was denied or a drug dropped, and hang up without an answer long before they fill out a form. A member who has called three times about one issue is not satisfied, yet first call resolution in health insurance is only about 72 percent,⁵ and for complaint calls just 47 percent.⁶ Traditional quality assurance reviews only 2 to 5 percent of calls,⁷ so the slow walk to disenrollment, and nearly every call in a language other than English, goes unheard.

Why the loss counts twice on the books

The cost shows up plainly. CMS caps broker pay at $694 for a new Medicare Advantage enrollment in 2026 and $347 for a renewal, so acquiring a member costs at least twice keeping one.⁸ In a churning market a plan pays that premium at volume, and winning a switcher only to lose them a year later to an unreviewed call means it bought nothing. On top sits the Star Ratings bonus: eligibility turns on the four star threshold, and a half star slip from 4.0 to 3.5 erases the entire 5 percent bonus,⁹ several million dollars a year for a midsize plan.

CMS just removed the disenrollment scorecard

The timing is unkind. On April 2, 2026, the Contract Year 2027 Final Rule removed 11 Star Ratings measures, including Members Choosing to Leave the Plan, the measure that graded plans on voluntary disenrollment, effective with the 2029 Star Ratings.¹⁰ That looks like relief, but nothing underneath it changed. CMS still fields the Disenrollment Reasons Survey and reports disenrollment publicly, CAHPS remains in the formula at double weight,¹¹ and a lost member still has to be replaced. CMS stopped keeping score in the very year a plan can least afford to look away.

What to look for in a way to see it coming

Finding these members while there is still time to act is a different exercise from grading agents on a sample. A plan should look for:

• Whole population analysis rather than sampling, so a single member's escalating calls and the patterns across the book are both visible.

• Scoring that reads the member, weighing sentiment, unresolved issues, and repeat contact, not just whether the agent's greeting was correct.

• The same rigor for every language, including interpreter lines, which Section 1557 of the Affordable Care Act makes a legal duty.

• Plan ownership of the data and scoring models, so the retention signal survives changes in vendors, staffing, and telephony.

• A direct link from calls to CAHPS, grievances, and disenrollment, so sentiment does not sit in a report no one connects.

This is the gap Claro by Mizzeto was built to close. Claro analyzes the full volume of member calls, including the languages and interpreter lines sampling never reaches, and its Member Sentiment & At-Risk Identification scoring surfaces the unresolved, escalating conversations that turn into disenrollment months later, for tenured and newly won members alike, while the plan keeps ownership of the data. For the upstream work, see how payers can fix their call centers.

The bottom line

For one year at least, retention is a contest a plan can lose on both sides at once. The reasons people leave Medicare Advantage plans are documented, they turn on usability more than price, and they surface on calls long before an enrollment form, for members of a decade or a week. CMS took away the measure. The cost, paid twice over in a churning market, did not fall.

References

1.  Johns Hopkins Bloomberg School of Public Health and Georgetown University, JAMA (Feb. 18, 2026): approximately 2.9 million Medicare Advantage members, about 10 percent of enrollees, faced forced disenrollment for 2026 as plans exited markets, up from a mean of 1 percent from 2018 to 2024 and 6.9 percent in 2025. jamanetwork.com

2.  Health Affairs, study of Medicare Advantage disenrollment using the Medicare Current Beneficiary Survey (2015 to 2020): difficulty accessing care associated with roughly 1.33 times greater likelihood of disenrollment; low plan generosity roughly 1.47 times; dissatisfaction with care quality significant; dissatisfaction with cost alone not a significant independent predictor (approx. 1.03 times). healthaffairs.org

3.  Centers for Medicare and Medicaid Services, Medicare Advantage and Prescription Drug Plan Disenrollment Reasons Survey. Captures why beneficiaries voluntarily leave; results publicly reported in the annual Star Ratings Data Table and Display Measures. cms.gov

4.  The Commonwealth Fund, analysis of CMS Medicare Advantage Disenrollment Reasons Survey data: approximately 18 percent of disenrollees cited problems getting the plan to cover services and approximately 13 percent cited customer service issues such as trouble obtaining accurate information; voluntary disenrollment across MA contracts rose about 70 percent between 2017 and 2021. commonwealthfund.org

5.  SQM Group, First Call Resolution Benchmarking by Industry: health insurance first call resolution approximately 72 percent. sqmgroup.com

6.  SQM Group, first call resolution by call type: complaint calls resolve on first contact approximately 47 percent of the time, the lowest of all call types. sqmgroup.com

7.  SQM Group, call center quality assurance benchmarking: traditional programs review roughly 2 to 5 percent of interactions. sqmgroup.com

8.  Centers for Medicare and Medicaid Services, Agent and Broker Compensation memorandum for Contract Year 2026 (June 18, 2025): national maximum Fair Market Value of $694 for a new Medicare Advantage enrollment and $347 for a renewal. cms.gov

9.  Centers for Medicare and Medicaid Services, Medicare Advantage Quality Bonus Payment methodology: bonus payments apply to contracts at or above the four star threshold; loss of four star status removes the 5 percent quality bonus applied to the benchmark. cms.gov

10.  Centers for Medicare and Medicaid Services, Contract Year 2027 Medicare Advantage and Part D Final Rule (April 2, 2026): removal of 11 Star Ratings measures, including Members Choosing to Leave the Plan, effective with the 2029 Star Ratings. cms.gov; Federal Register, April 6, 2026.

11.  Centers for Medicare and Medicaid Services, 2026 Medicare Part C and D Star Ratings Technical Notes: CAHPS and patient experience measure weights reduced from quadruple (4x) to double (2x) effective with the 2026 Star Ratings. cms.gov

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By the time a formal grievance reaches a health plan’s Grievance and Appeals team, it arrives looking like an emergency. The member is angry. A response deadline is already running. A regulator may eventually read the file. What the file rarely shows is that the grievance did not begin that week, or even that month. It began on an ordinary call that did not get resolved and was never reviewed. The warning was there. No one was assigned to look for it.

Most health plans treat reducing member grievances as a downstream chore: staff the queue, meet the deadline, close the case. That posture quietly concedes the grievance as inevitable, and it is not. A grievance is the visible end of an escalation that usually runs about six weeks, and nearly all of it is recorded, in the plan’s own phone system, in the member’s own words. The signal is not missing. It is simply never listened to.

A grievance is a six week escalation, not a single event

CMS defines a grievance as a complaint about a plan’s delivery of service, and the rules let a member arrive there slowly. A Medicare Advantage enrollee has up to 60 days after the triggering event to file, and the plan then has 30 days to resolve a standard grievance, with a 14 day extension.⁵ That window is the outer edge of a story that almost always starts earlier, on the phone.

The arc is familiar to any member services team. It opens with a single call about a denied claim, a benefit change, or a stalled prior authorization, and the member hangs up with an answer that is incomplete or simply wrong. That is common. SQM Group puts first call resolution for health insurance at roughly 72 percent, so close to three in ten member calls are not settled the first time.¹ The member calls back, and calls again, and these repeat calls are the hardest to fix, because complaint calls resolve on the first contact only 47 percent of the time, the lowest rate of any call type SQM tracks.² By the fifth or sixth week the member gives up and files. Only then does the plan open a case.

The shape of it is mundane. A member is told on the phone that a drug is covered, learns at the pharmacy counter that it is not, gets a different answer from a second agent, and files after a third. Three recorded calls, one avoidable grievance, and a member now drifting toward disenrollment. Every call was captured. None was flagged.

Appeals run on the same current. A denial explained badly prompts an appeal, not just frustration. The recording of that call is the clearest account of what the member was told, and the one document the appeals file rarely contains. A single unreviewed call can feed both outcomes, a grievance about the service and an appeal against the decision, both audible weeks before either was filed.

Why the warning stays invisible

The reason is not indifference. It is arithmetic. Traditional call center quality assurance, whether member service is run internally, outsourced, or split between the two, reviews somewhere between 2 and 5 percent of calls.³ The other 95 percent, which includes nearly every repeat call in an escalating grievance, is never heard by anyone whose job is to catch problems. A sample that small will almost never contain the three or four particular calls that make up one member’s slow walk to a filing, and it is even less likely to reveal the shape of the trouble when the same benefit is being miscommunicated to hundreds of members at once.

Sample size is only half of the failure. The deeper flaw is what the sampling was built to measure. A conventional scorecard asks whether the agent greeted the member, verified identity, and read the required disclosures. It does not ask whether the member’s problem was actually solved, or whether the member hung up angrier than they picked up. A call can earn a clean score and still be a grievance in motion. The program was designed to grade etiquette, and etiquette is not the thing that turns into a filing. We have made this case before, that most grievances start as calls that never got reviewed, and nothing in the underlying mechanics has changed since.

The calls in languages other than English are the least visible of all. When a member with limited English proficiency cannot be helped without an interpreter, the quality of the resolution is harder to verify, the member is less likely to push back on an answer they do not fully understand, and the interaction is almost never scored at all. Those are precisely the calls where a small misunderstanding hardens, unseen, into a grievance.

CMS just removed your grievance scorecard

On April 2, 2026, CMS issued the Contract Year 2027 Medicare Advantage and Part D Final Rule and, with it, removed 11 measures from the Star Ratings. Four of them speak directly to this problem, and all four leave the formula beginning with the 2029 Star Ratings: Complaints about the Health and Drug Plan, Members Choosing to Leave the Plan, Plan Makes Timely Decisions about Appeals, and Reviewing Appeals Decisions.⁴ Read in a hurry, that looks like a reprieve. The measures that once turned complaints, disenrollment, and appeals handling into a Star score are going away, and the natural temptation is to slide grievance and appeals monitoring down the list of things worth watching.

That reading has it exactly backward. The measures are leaving the scorecard. The exposure is staying exactly where it was. CMS still runs the Complaints Tracking Module, and plans are still bound to the resolution timelines set at 42 CFR 422.125 and 422.564.⁵ The complaint and customer service questions remain on the CAHPS survey, and the survey based measures carry heavy and rising weight in the Medicare Advantage formula.⁶ A member who leaves still leaves. What actually changed is narrower and more dangerous than relief: the warning light that used to sit on the Star dashboard has gone dark. Plans that had quietly relied on those measures as their grievance scorecard now have no scorecard, and precisely the same risk underneath it.

What it takes to see it coming

Seeing a grievance coming means catching the escalation while it is still a service problem, not a case number. It rests on a reversal: stop sampling calls to grade agents, and start reading all of them to find members. A plan that analyzes every interaction can connect the several calls behind one escalation and watch the same complaint surface across the population, where a single systemic fix replaces hundreds of grievances not yet filed.

The point is not more scores but earlier ones. A member who has called three times about one decision is a retention risk however politely each call was handled, and no rubric that grades greetings will say so. A few practical tests separate a system that sees a grievance coming from one that only counts calls afterward:

• Whole population analysis, not sampling, so one member’s escalating calls and the patterns forming across the book are both visible before anyone files.

• Scoring that reads the member, not just the agent, weighing sentiment, unresolved issues, and repeat contact rather than whether the greeting was correct.

• The same rigor for calls in every language, including interpreter lines, because that is where hidden escalation collects and Section 1557 makes language access a legal duty.

• Plan ownership of the conversation data, scoring models, and trend lines, so the early warning system survives changes in telephony and staffing and can be retuned in days.

• Alerts that reach the people who can act, so member services, grievance and appeals, and compliance see a trend while there is still time to intervene.

Two ways to run grievance and appeals operations

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Mizzeto built Claro for exactly this gap. It analyzes the full volume of member calls, including the ones in other languages and on interpreter lines that sampled QA never reaches, and its Member Sentiment & At-Risk Identification scoring is built to surface the unresolved, escalating conversations that become grievances and appeals weeks later, all while the plan keeps ownership of the underlying data and the logic that scores it. If a grievance and appeals team is meeting every deadline and still watching volume climb, the explanation is usually sitting in calls the plan has already recorded and has never had a way to hear.

The bottom line

A formal grievance is the most expensive way a health plan can learn about a problem it could have seen six weeks earlier. The information was never missing. It was sitting, unheard, in the 95 percent of calls no one reviews. CMS has taken away the measures that once forced plans to watch their complaints and their appeals, but the price of a grievance, paid in CAHPS, in disenrollment, and in compliance exposure, has not fallen by a cent. Reducing member grievances begins with a decision to stop waiting for them to arrive.

Any plan can find out what its own calls are already saying. Mizzeto will score a sample of them and show a plan the warnings hidden inside before it commits to anything further. For the upstream work that keeps these calls from going wrong in the first place, see how payers can fix their call centers.

References

1.  SQM Group, “First Call Resolution Benchmarking by Industry” (health insurance first call resolution approx. 72 percent). sqmgroup.com

2.  SQM Group, first call resolution by call type (complaint calls resolve at 47 percent, the lowest of all call types). sqmgroup.com

3.  SQM Group, call center quality assurance benchmarking (traditional programs review roughly 2 to 5 percent of interactions). sqmgroup.com

4.  Centers for Medicare & Medicaid Services, “Contract Year 2027 Medicare Advantage and Part D Final Rule,” April 2, 2026 (removal of 11 Star Ratings measures, including Complaints about the Health and Drug Plan, Members Choosing to Leave the Plan, Plan Makes Timely Decisions about Appeals, and Reviewing Appeals Decisions, effective with the 2029 Star Ratings). cms.gov; Federal Register, April 6, 2026.

5.  42 CFR 422.564 (grievance procedures: 60 day filing window, 30 day standard resolution, 14 day extension) and 42 CFR 422.125 (resolution of complaints in the Complaints Tracking Module). ecfr.gov

6.  Analysis of the CY2027 Final Rule finding relative Star Ratings weight shifting toward survey based measures such as CAHPS for Medicare Advantage plans (e.g., Crowell & Moring; Holland & Knight client alerts, April 2026).

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