For special needs plan sponsors  ·  The 2027 Star Ratings were published October 8, 2026

For D-SNP sponsors

Medication safety, run by a pharmacist on your care team.

A Clinical Pharmacist, genetic science and whole-regimen review move your members off harmful and ineffective drugs and onto treatments that work. The result for your plan: measurable improvement in utilization costs and Star Ratings.

Schedule a 30-minute call See what we do
A ChorusRx Clinical Pharmacist talking with an older patient about his medications, with a genetic testing kit and prescription bottles on the table
I-SNPA pharmacist on site, beside your care team
C-SNPCondition by condition, by video visit
D-SNPA pharmacist on your care team
Every planMedication safety, member by member
  1. A pharmacist on your team Inside your care team, beside the prescribers
  2. Genetics and the whole regimenEvery drug, interaction and gene read together
  3. Off the wrong drugs, onto the right onesAway from harmful and ineffective medications
  4. Measurable results for your planLower utilization costs. Higher Star Ratings.

Focus on

I-SNP: institutional. D-SNP: dual-eligible. C-SNP: chronic condition. Pick yours to see the program as it applies to you.

What we do

We find the members at risk, a pharmacist reviews, your prescriber decides, and you can show the result

ChorusRx is a pharmacist-led layer on the care model you already run. Five steps, from your claims data to a documented medication decision. We recommend. Your prescriber decides.

  1. 1

    Start from data you already hold

    Your enrollment roster and medical and Part D claims, under a data use agreement. Medication lists or eMAR exports for the highest-risk members are optional.

    Your plan
  2. 2

    Rank medication risk across every member

    Whole-regimen scoring surfaces anticholinergic and sedative burden, nine-plus medications, risky combinations, adherence gaps and recent discharges.

    ChorusRx analytics
  3. 3

    A Clinical Pharmacist reviews the highest-risk regimens

    Each regimen is read as a whole. Pharmacogenomic (PGx) testing is added only where a genotype would change a pending drug decision.

    ChorusRx pharmacist
  4. 4

    The recommendation goes to the person who decides

    The prescriber, nurse practitioner or care manager gets the reason and an alternative, then accepts, modifies or declines. The decision is documented.

    Prescriber decides
  5. 5

    Report against the measures you are held to

    Measure-level reporting, leading indicators monthly, Star and claims results as they arrive. Performance guarantees are negotiated case by case.

    Your quality team
It repeats. The ranked cohort refreshes as claims arrive, and a discharge or a new high-risk prescription puts a member back at the front of the line.

Your team ChorusRx The decision stays with the prescriber

In a D-SNP

Steps 3 and 4 sit inside the interdisciplinary care team and the individualized care plan that every SNP must run,1 with the findings shared with the care manager. We coordinate with your Part D MTM program so a member is not reviewed twice for the same purpose.2 We do not replace your health risk assessment or care plan.

One member, illustrated A composite example for explanation only. Not a real member, and not a result.

  1. FlaggedTakes nine medications, two with anticholinergic effects, and was discharged last week. Ranked near the top of the cohort.
  2. ReviewedThe pharmacist reads the whole regimen and notes a pending antidepressant decision where a genotype could matter.
  3. RecommendedA short note to the prescriber: what was found, why it matters and the options. Testing is ordered only if the prescriber agrees.
  4. DecidedThe prescriber accepts, changes or declines. The decision and the reason are documented in the record.
  5. CountedThe review and its outcome feed the measures the plan is held to, and the member stays on the monthly refresh.

What you receive

  • A ranked medication-risk cohortEvery member scored, refreshed monthly.
  • Pharmacist review notesMember-level recommendations, routed to the prescriber or care manager.
  • Interpreted PGx resultsOnly where a drug decision is pending, read against the full regimen.
  • Measure-level reportingMapped to the Star, Part D and Model of Care measures you are held to, not to activity counts.
Walk through it with a Clinical Pharmacist

Around every member

A pharmacist inside the team that cares for the member.

Member Primary careclinician Nurse caremanager Behavioral healthclinician Social worker Family orcaregiver ChorusRx Clinical Pharmacist on the care team

The prescriber still decides.

Where we plug in

Four measures you are held to. Four things a pharmacist can do about them.

Your care managers already run the Model of Care. We add a Clinical Pharmacist to the care team and aim the medication work at the measures that count.

  • 3×
    Part D adherenceDiabetes drugs, RAS antagonists, statins3

    Find the late and lapsed fills, ask why, and take the answer to the prescriber or care manager: a side effect, a regimen that is too complex, a plan of care that changed.

  • SNP-only
    Care for Older Adults: medication reviewA clinical pharmacist's review counts3

    Pharmacist reviews of the highest-risk members, documented in the plan's record in a form that supports the measure.

  • New 2027
    Anticholinergic burden and opioid–benzodiazepine co-usePoly-ACH and COB3

    Score every member's regimen, flag the combinations, review the highest-risk members and recommend alternatives to the prescriber.

  • Back in 2029
    Medication therapy management reviewThe annual comprehensive medication review2

    Deliver the annual review for eligible members and coordinate with your care managers so that no member is reviewed twice for the same purpose.

Why ChorusRx

Six reasons SNP sponsors work with us

We are not a generic medication therapy management vendor adapting to special needs plans. Our model was built around frail, multi-chronic older adults, including people at the nursing-facility level of care.

  1. 1

    Built for frail, multi-chronic older adults

    PACE participants must be certified as needing nursing-facility level of care,4 the same acuity I-SNPs enroll. Our model was built and operated in full-risk programs serving frail, multi-chronic older adults, where a preventable admission has nowhere to hide.

  2. 2

    We work with your clinicians and pharmacists, not around them

    Your clinicians make the care decisions and your own pharmacists may already review charts. Our Clinical Pharmacists work as part of the care team, in collaboration with the prescriber, and design the work to avoid reviewing the same member for the same purpose twice.

  3. 3

    A plan-level view no single clinic or facility has

    Claims and Part D data across your whole book show where anticholinergic and sedative burden, psychotropic use and risky transitions concentrate. Reporting maps to the measures you are held to and, for institutional plans, to the metrics your facility partners are paid on, not to activity counts.

  4. 4

    Genomics inside the review, not beside it

    PGx is core to how our Clinical Pharmacists work, applied where a published guideline says genotype changes a decision and read against the whole regimen. The science is established, and we know how to apply it.

  5. 5

    We take risk alongside you

    ChorusRx offers value-based partnering agreements with performance guarantees and shares financial risk when outcomes are not achieved. Guarantees are underwritten to your population and negotiated case by case, once we have seen enough of your data to commit honestly.

  6. 6

    Built to sit inside your Model of Care

    A Clinical Pharmacist role in the interdisciplinary care team, documented in the Model of Care and the care plan, without replacing your health risk assessment, your care managers or your enrollment processes.

The economics

Medication spend is your money, and your Star Ratings are your payment.

Part D drug cost, and the share plans carry

14%2021
57%2026
Plan liability, the part of Part D spending financed through Medicare's direct subsidy and beneficiary premiums, rose from 14% in 2021 to a projected 57% in 2026 as the redesigned benefit moved cost from beneficiaries and Medicare to plans.5

After a member's $2,400 out of pocket, who pays the next drug dollar?6

  • Plan sponsor (you)
  • Manufacturer discount
  • Medicare reinsurance
Typical shares in the catastrophic phase, for applicable drugs. The member pays nothing, so the plan's share is the exposure.

What your Star Rating is worth in payment7

Rebate share is the part of the plan's bid savings returned as rebate; the bonus is a benchmark add-on that doubles in qualifying counties. The 2027 Star Ratings set 2028 payments.
  • Drug spend you can influenceDuplicative, unnecessary and high-risk therapy is a cost as well as a safety issue. We find it in your Part D data.
  • Measures that move the ratingEach Part D adherence measure counts triple in the Star Ratings.3
  • Spend that counts toward your 85%Medication therapy management that meets Part D requirements counts as quality-improvement spend in the medical loss ratio.8
  • Risk shared with youChorusRx shares financial risk through performance guarantees, negotiated case by case.
  • Dual-eligible beneficiary$25,871
  • Other Medicare beneficiary$11,834
Per-person Medicare spending in 2022: more than twice as much for dual-eligible beneficiaries.9

Bring your Part D data and we will size the opportunity with you before you commit.

What D-SNPs are measured on

The Part D measures reach D-SNPs in full, and the SNP-only measures add a pharmacist-friendly one.

Every measure you are held to has a lever on our side.

See the full table: what you are held to and how we help
What D-SNP sponsors are held to, mapped to medication mechanisms and ChorusRx interventions
What you are held to Type The medication mechanism What ChorusRx does about it
SNP Model of Care and health risk assessment Regulatory An NCQA-approved Model of Care (up to three years by score), an HRA within 90 days (before or after) of enrollment and every year, and an individualized care plan built with an interdisciplinary care team; HRA results must be addressed in the care plan.1 A Clinical Pharmacist role inside the interdisciplinary team and medication goals documented in the care plan. We support your HRA and care plan; we do not replace them. Model of Care changes can be filed for NCQA review in the off-cycle windows.10
Part D adherence (diabetes, RAS antagonists, statins) and Statin Use in Persons with Diabetes Star (Part D) Calculated from dispensing records. Each adherence measure is triple-weighted; Statin Use in Persons with Diabetes carries a weight of 1.3 Outreach on stopped or late fills with a pharmacist's read on why, such as regimen complexity, side effects or a changed plan of care, routed to the prescriber or care manager.
Care for Older Adults: Medication Review Star, SNP-only The numerator needs a medication review by a prescribing practitioner or a clinical pharmacist, plus a medication list, for enrollees 66 and older. CMS collects it only from SNPs.3 Pharmacist reviews documented in the plan's record in a form that supports the measure.
Anticholinergic burden and opioid–benzodiazepine co-use (Poly-ACH and COB) Star (Part D, new) Both joined the Part D Star Ratings for 2027, each with a weight of 1.3 Whole-regimen anticholinergic and sedative burden scoring across enrolled members, then pharmacist review of those flagged, with recommendations to the prescriber.
Part D MTM comprehensive medication review (CMR) Part D, returns 2029 The completion rate is display-only now and returns as a Star measure in the 2029 ratings.3 In a study of community-dwelling beneficiaries 66 and older, completion among members the plans defined as eligible rose from 10.2% in 2013 to 35.8% in 2020. Dual-Medicaid enrollees' completion rose faster after 2016 but stayed below that of members with neither Medicaid nor the low-income subsidy.11 CMRs and targeted reviews delivered to eligible members, coordinated with your care managers so a member is not reviewed twice for the same purpose.
Plan All-Cause Readmissions and Transitions of Care Star Readmission is triple-weighted; Transitions of Care carries a weight of 1 and includes medication reconciliation after discharge.3 Medication reconciliation with pharmacist review of high-risk additions in the first days after discharge, shared with the care manager and prescriber.
Part D plan liability Financial Under the redesigned benefit, plan sponsors typically pay 60% of catastrophic-phase drug costs.6 Therapy that is duplicative, unnecessary or high-risk for a given member is a cost as well as a safety issue. Identification of that therapy in your Part D data, sized with you.

Scroll the table horizontally on smaller screens.

The differentiator

A medication review shows what a member takes. Genotype shows how they will respond.

We test where a genotype changes the decision, and a pharmacist reads each result against the member's whole regimen.

GENOTYPE DOSE CHECK

Illustrative: for a CYP2C19 poor metabolizer, the Clinical Pharmacogenetics Implementation Consortium (CPIC) advises considering a lower citalopram or escitalopram dose or a different antidepressant.12

Guidelines exist for drugs members actually take

CPIC publishes genotype-based guidance for SSRI antidepressants such as citalopram, escitalopram and sertraline, tricyclics, codeine and tramadol, clopidogrel, proton pump inhibitors, statins and warfarin.12

The pharmacist matters as much as the test

Genotype is only part of the picture. Interacting drugs can change how a member metabolizes a medication, a shift called phenoconversion: researchers found 280 phenoconversion events among 100 participants in the Program of All-Inclusive Care for the Elderly (PACE).13 Reading a result against the whole regimen, and deciding what to do with it alongside the prescriber, is clinical work a test report alone does not do.

Where it applies in a D-SNP

Genotype guidance is best developed for antidepressants, tricyclics, codeine and tramadol, and proton pump inhibitors.12 Those are common drugs in behavioral health and pain regimens, and pharmacogenomics tells the prescriber which ones a member will handle well.

Option A  ·  The plan-level program

Medication management across your SNP book

ChorusRx runs the medication program end to end: risk stratification from your claims and Part D data, Clinical Pharmacist review in collaboration with your NPs and attending physicians, targeted PGx where a drug decision is pending, and measure-level reporting by cohort (and by facility, for institutional plans), with performance guarantees negotiated case by case.

For plans, especially smaller or provider-sponsored plans, that cannot staff a clinical pharmacy team of their own.

Option B  ·  If you already have a program

The genetic intelligence layer

Already working with consultant pharmacists, an MTM vendor, a pharmacy benefit manager or your own clinical pharmacists? Keep them. ChorusRx supplies PGx testing, interpretation and decision support that flows into their process.

Testing is targeted and decision-triggered. We review with you how it is covered under your plan's policy.

Size the opportunity

What could the savings be worth in your D-SNP?

D-SNP bids average $1,427 per member per month.14 A Kentucky Medicare Advantage program that paired pharmacogenomics with pharmacist management saved $218.34 per member per month.15 Slide to see what a share of that could mean across your enrollment.

Your enrollment in the contract. The median D-SNP contract has about 6,000 members; a quarter have fewer than 1,500 and a quarter more than 18,900.16

The Kentucky program saved about 7% to 8% of medical cost (our arithmetic from the study's figures). Set it to what you would count as a win.15

What those savings are worth, per year

$0

per member per month

Medical cost per member per month14$1,427
Medical cost across your enrollment, per year$0
Savings per member per year$0

An illustration of scale from the average D-SNP bid (2025, the latest published by plan type). Your own claims give the exact figure, and we size it with you.

How it runs

From data agreement to measure-level reporting

We do not need a long integration project before producing something useful. Risk stratification runs off the claims and enrollment data a plan already holds, so the first ranked work list can exist within weeks.

Start the conversation

Now – December 31, 2026

Scope and data

Data use agreement, enrollment roster, a facility or provider list where relevant, and medical and Part D claims. Conversations with your clinical and pharmacy leads to agree who reviews what. If you want a pharmacist role documented in your Model of Care, the off-cycle window for changes, open to D-SNPs and I-SNPs, runs through December 31.10

Q1 2027  ·  First wave

Review where it counts

A ranked medication-risk cohort, pharmacist review of the highest-risk members in collaboration with the prescriber, transition reconciliation for hospital returns, and PGx testing where a drug decision is pending.

Mid-2027  ·  Plan-year 2028 bids

Scale and instrument

Monthly cohort refresh, facility- or cohort-level reporting, and the first two quarters of process data on anticholinergic and sedative burden, psychotropic use and transitions in hand for bid planning. By statute, bids are due on the first Monday in June, which in 2027 is June 7.17

2028 – 2029

Compound

Reporting continues against Poly-ACH and opioid–benzodiazepine measures already in the Star Ratings, and against the MTM completion measure that returns in the 2029 ratings.3 We will adapt the reporting to whatever CMS decides on special needs plans.

The proof

The science is proven. We know how to apply it.

Gene-drug effects are established, published guidelines tell prescribers what to do about them, and the results are in.

25%fewer

Adverse drug reactions

Genotype-guided prescribing lowered clinically relevant adverse drug reactions from 28.6% to 21.5% in a randomized trial of 6,944 patients across seven countries.18

>50%fewer

Rehospitalizations

PGx testing plus pharmacist review cut 60-day rehospitalizations in older home-health patients, from 0.70 to 0.33 per patient, in a randomized trial.19

$5,024

Lower cost growth

Per participant per year in 19 PACE organizations using structured medication risk mitigation, serving people who need a nursing-facility level of care.20

14.9%fewer

Inpatient events

Medicare retirees aged 65 and older in a pharmacogenomics-enriched pharmacist program also had $218.34 lower medical cost per member per month (5,288 members, 32 months).15

7

Drug families with published guidelines

SSRIs, tricyclics, codeine and tramadol, clopidogrel, proton pump inhibitors, statins and warfarin all have genotype-based guidance from the Clinical Pharmacogenetics Implementation Consortium.12

280

Why a pharmacist reads every result

Researchers found 280 phenoconversion events, where one drug changes how a gene behaves, among 100 PACE participants. A test report alone cannot see that.13

0.39

Better prescribing, better adherence

Across 17 trials, pharmacist-led multidisciplinary reviews of older adults improved medication appropriateness (odds ratio 0.39) and adherence (risk ratio 1.14).21

Our founder, Calvin H. Knowlton, co-authored the PACE pharmacogenomics research cited in note 13 and has spent his career building medication-safety programs for frail, multi-chronic older adults. We will walk you through client results under NDA.

Questions SNP sponsors ask

Practical answers

No. We work with them. The facility or plan processes you already run stay as they are, we work from the information those teams produce and from your claims and Part D data, and we design the work so that a member is not reviewed twice for the same purpose. Where fulfillment itself is the gap, such as community-based members who need packaging organized by time of administration, we can provide pharmacy management including Precision Compliance Packaging.

Yes, for the drug decisions where it matters. Published guidelines cover the commonly used drugs, and in a randomized trial of 6,944 patients a 12-gene panel with guideline-based prescribing lowered clinically relevant adverse drug reactions from 28.6% to 21.5%. We test where a genotype would change a decision, not everyone, and a pharmacist interprets each result against the member's whole regimen because interacting drugs can change how a gene behaves.

A Clinical Pharmacist reads each member's whole regimen together: interactions, anticholinergic and sedative burden, duplicate therapy and drugs that may no longer be needed. The prescriber receives the reason and an alternative, such as a dose change or deprescribing a drug, and accepts, modifies or declines. We recommend. Your prescriber decides.

To start: the enrollment roster and medical and Part D claims, under a data use agreement, plus a facility or provider list where relevant. Optional but valuable: medication lists or electronic medication administration record exports for the highest-risk members. You receive a ranked medication-risk cohort, member-level recommendations routed to the prescriber or care manager, and plan-level reporting mapped to the measures you are held to rather than activity counts. Please do not send protected health information through this website; clinical data exchange happens under a signed agreement.

Commercial terms are negotiated per client. Engagements are commonly structured as a per-member-per-month fee, a shared-savings arrangement, or a hybrid with performance guarantees attached. Testing is targeted rather than universal, and how it is funded depends on your plan's coverage policy and the commercial arrangement; we model the options against your population before you commit.

Yes. We offer value-based partnering agreements with performance guarantees and share financial risk where outcomes are not achieved. We will discuss specific guarantee structures once we have seen enough of your data to underwrite them.

Review volume and medication-risk measures such as anticholinergic and sedative burden can move within the first 60 to 90 days. Claims-based utilization and Star Ratings measures follow as claims run out and the measurement year closes. We report leading indicators monthly, so you see the program working long before settlement data arrives.

ChorusRx contracts with the plan or its sponsor as a vendor and clinical service partner. We do not enroll members, market to beneficiaries or bill Medicare for your enrollees. Arrangements involving facilities or provider groups, incentive payments and data sharing should be reviewed by your own counsel and compliance team, and we will support that review with whatever documentation they need.

Start with the parent organization's leaders who own the plan's medication and quality results: Part D and pharmacy, Star Ratings and quality, and the Medicare clinical and Model of Care lead. Where the plan is paired with a Medicaid managed care plan under the same parent, add that plan's clinical and pharmacy leadership and whoever runs dual-eligible integration. The form on this page asks which one you are so that we route the first call correctly.

Fewer inappropriate and high-risk medications, better adherence, and medication work documented in a form that supports the measures you are held to, including the triple-weighted adherence measures and the medication review measure that only special needs plans report. Pharmacist-led reviews of older adults have improved medication appropriateness and adherence across 17 randomized trials.

Beginning in 2027 a dual-eligible special needs plan's new enrollment is tied to the members of an affiliated Medicaid managed care plan where the same organization holds both, which puts the parent organization at the table. We do not change your health risk assessment, enrollment or Medicaid contracting. We work inside the care team, share what we find with your care managers, and report against the Medicare measures you are held to. Have your own counsel review how any vendor arrangement fits your state Medicaid agency contract.

No. Part D plans must offer an annual comprehensive medication review to members enrolled in their medication therapy management (MTM) program, and the completion rate returns as a Star measure in 2029. We can deliver those reviews or work alongside whoever does, and we coordinate so a member is not reviewed twice for the same purpose.

Next step

Thirty minutes, before plan-year 2028 planning

A working session with a ChorusRx Clinical Pharmacist, not a capabilities deck. Bring your enrollment, your provider or facility mix and how medication work is organized today, and we will map medication risk against the measures you are held to.

  • A read on where medication risk likely concentrates in your enrolled population
  • Your Model of Care, Star and Part D measures mapped to specific, nameable interventions
  • An honest view of what the evidence supports and what you would need to measure
  • How a pharmacist role would sit alongside your care team, NPs and consultant pharmacists where you have them
  • Contracting options, including performance-guarantee structures

Request a medication-risk call

We reply within one business day.

We use your details only to arrange and prepare for this conversation. See the ChorusRx privacy policy. No protected health information, please — clinical data exchange happens under a data use agreement.

Sources & notes
  1. 42 CFR 422.2, 422.101(f) and 422.152(g) (eCFR, current as of October 28, 2026).
    • Definitions of I-SNP and its subtypes: institutionalized (residing or expected to reside 90 days or longer in a qualifying facility) and institutionalized-equivalent (living in the community but requiring an institutional level of care).
    • Model of Care: initial and annual health risk assessment, an individualized care plan developed through an interdisciplinary care team, trained staff, and National Committee for Quality Assurance (NCQA) approval of one to three years by score (85% or higher for three years). Every I-SNP Model of Care must ensure contracts with long-term care institutions allow I-SNP clinical and care-coordination staff access to enrollees (422.101(f)(2)(vi)).
    • Quality program measures may include medication reconciliation at care-setting transitions and measures from the medication management domain (422.152(g)). The regulation does not require a standalone pharmacist or medication review role.
    • C-SNP Model of Care approvals are limited to one year (422.101(f)(3)(iii)); I-SNP and D-SNP approvals run 3 years at 85% or higher, 2 years at 75–84% and 1 year at 70–74%. HRA within 90 days (before or after) of enrollment and annually; individualized care plan within 90 days; an applicable integrated plan (a D-SNP with aligned Medicaid enrollment) must use a single integrated assessment beginning no later than contract year 2027 (422.101(f)(1)). Off-cycle Model of Care windows (January 1–March 31 and October 1–December 31) are for D-SNPs and I-SNPs; changes go to NCQA for review. Separately, 422.52(f) requires a C-SNP to have the enrollee's physician, physician assistant or nurse practitioner confirm the qualifying condition before enrollment (or by the end of the first month using a qualification tool) and to disenroll the member if it is not verified.
  2. Centers for Medicare & Medicaid Services. Medication Therapy Management Program Standardized Format FAQs. Revised August 15, 2012; 42 CFR 423.153(d) and 423.154 (eCFR, October 28, 2026).
    • Plans must offer a comprehensive medication review at least annually to all MTM-enrolled beneficiaries, including those in long-term care settings; for cognitively impaired beneficiaries it may be done with the prescriber, caregiver or authorized individual.
    • Pharmacies serving long-term care facilities must dispense solid oral brand-name drugs in increments of no more than 14 days (42 CFR 423.154).
    • 42 CFR 423.153(d)(2): a sponsor's MTM program must enroll members who have multiple chronic diseases (a sponsor may require no more than three), take multiple Part D drugs (no more than eight) and are likely to incur covered Part D costs at or above CMS's threshold ($1,340 for 2027; $1,276 for 2026, from CMS's annual MTM submission memos of May 1, 2026 and May 6, 2025), plus at-risk beneficiaries. The sponsor must include ten core chronic diseases, among them heart failure, diabetes, dyslipidemia, hypertension and respiratory disease. The CMR is an interactive consultation by a pharmacist or other qualified provider, in person or by synchronous telehealth.
  3. Centers for Medicare & Medicaid Services. 2027 Part C & D Star Ratings Technical Notes. Updated September 30, 2026; and CMS, 2027 Medicare Advantage and Part D Star Ratings [fact sheet], October 8, 2026.
    • Star Ratings data are reported at the contract level; SNP measure data are collected at the plan benefit package level and combined into contract-level rates. A contract that offers only I-SNPs is rated in its own category ("CCP with Only I-SNP") with fewer required measures (9 of 17 Part C and 5 of 10 Part D), and the CAHPS member experience domains are not applicable to it.
    • SNP-only measures: SNP Care Management (health risk assessment, HRA, completion) and Care for Older Adults medication review (enrollees 66+) and functional status assessment. Plan All-Cause Readmissions is triple-weighted; Transitions of Care and Follow-up after Emergency Department Visit for Multiple High-Risk Chronic Conditions carry no I-SNP exclusion.
    • Part D: adherence for diabetes medications, RAS antagonists and statins (triple-weighted; the proportion-of-days-covered calculation adjusts for inpatient stays and Medicare Part A covered skilled-nursing stays), Statin Use in Persons with Diabetes, and, new for 2027, concurrent opioid–benzodiazepine use and anticholinergic polypharmacy (Poly-ACH).
    • The MTM comprehensive medication review completion rate is display-only for measurement years 2025 and 2026 and returns as a Star measure in the 2029 ratings. Several HEDIS measures (for example breast cancer screening, colorectal screening, eye exam for diabetes, kidney health evaluation, blood pressure control and statin therapy for cardiovascular disease) exclude Medicare members 66 and older who are enrolled in an I-SNP or living long-term in an institution. The Technical Notes list no such exclusion for Plan All-Cause Readmissions, Transitions of Care, Follow-up after Emergency Department Visit for Multiple High-Risk Chronic Conditions or Care for Older Adults; the full HEDIS specifications were not reviewed.
    • Weights (Attachment G, resolved by table position): intermediate-outcome and outcome measures 3 (Part D adherence for diabetes medications, RAS antagonists and statins; Plan All-Cause Readmissions); process measures 1 (Statin Use in Persons with Diabetes, COB, Poly-ACH, Care for Older Adults medication review and functional status, Transitions of Care, SNP Care Management); new measures count 1 in their first year. The Care for Older Adults measures are SNP-only (HEDIS measurement year 2025, enrollees 66 and older). CMS finalized removal of SNP Care Management from the 2029 Star Ratings and of Statin Therapy for Cardiovascular Disease from 2028.
  4. 42 CFR 460.150(b)(2), Eligibility to enroll in a PACE program (eCFR/LII).
    • A person must be determined by the State administering agency to need the level of care required under the State Medicaid plan for coverage of nursing facility services.
  5. Medicare Payment Advisory Commission. The Medicare prescription drug program (Part D): Status report. Chapter 13 in Report to the Congress: Medicare and the Health Care Delivery System. March 2026.
    • Plan liability, financed through Medicare's direct subsidy and beneficiary premium payments, rose from 14% of Part D spending in 2021 to a projected 57% in 2026; MedPAC attributes 82% of the growth in plans' unstandardized bids between 2024 and 2025 to the shift toward plan liability. Moving catastrophic cost sharing to plans shifted liability from beneficiaries and Medicare's low-income subsidy to plans.
    • Figure 13-1 shows the 2026 phase split: catastrophic phase plan 60%, manufacturer 20%, Medicare 20%; initial coverage plan 65%, manufacturer 10%, enrollee 25%.
  6. Centers for Medicare & Medicaid Services. Announcement of Calendar Year (CY) 2027 Medicare Advantage Capitation Rates and Part C and Part D Payment Policies. April 6, 2026.
    • Part D annual out-of-pocket threshold: $2,100 (2026) and $2,400 (2027). The 2025 figure of $2,000 is from CMS's Final CY 2025 Part D Redesign Program Instructions (cms.gov/files/document/final-cy-2025-part-d-redesign-program-instructions.pdf).
    • CMS keeps the 2024 CMS Hierarchical Condition Category (CMS-HCC) risk adjustment model for 2027; the announcement contains no I-SNP-specific payment policy.
    • CY2027 final rule (note 10): in the catastrophic phase, Part D plan sponsors typically pay 60% of covered drug costs.
    • Phase shares (Final CY2026 Part D Redesign Program Instructions, Section 20; MedPAC March 2026 Chapter 13, Figure 13-1): in the catastrophic phase plan sponsors typically pay 60% of covered drug costs, manufacturers 20% and Medicare reinsurance 20% for applicable drugs (40% for other drugs). We did not find a CY2027 program-instruction document restating the percentages; the CY2027 final rule describes the defined standard benefit the same way. National average monthly bid: $179.45 (2025), $239.27 (2026), $296.05 (2027).
  7. Centers for Medicare & Medicaid Services. Advance Notice of Methodological Changes for Calendar Year (CY) 2027 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies (Tables II-2 and II-3), continued in the CY2027 Rate Announcement; and CMS, 2027 Medicare Advantage and Part D Star Ratings fact sheet, October 8, 2026.
    • Quality bonus payment: plans rated 4, 4.5 or 5 stars receive a 5-point add-on to the county benchmark (applicable percentage), doubled to 10 points in qualifying counties; plans below 4 stars receive none (42 CFR 422.258(d)(7)).
    • Rebate percentage (the share of the bid-to-benchmark savings returned as rebate): 70% at 4.5 stars or more, 65% from 3.5 to under 4.5 stars, 50% below 3.5 stars (42 CFR 422.266(a)(2)). MedPAC's March 2026 Chapter 12 states the same range.
    • Timing: the 2027 Star Ratings "will impact 2028 MA quality bonus payments" (CMS fact sheet). There is no separate rule for SNP-only or I-SNP-only contracts; new and low-enrollment contracts receive a 3.5-point add-on and are treated as 3.5 stars for rebates, which MedPAC's June 2025 chapter (note 14) reports reaches many I-SNP enrollees.
  8. 42 CFR 422.2410, Medical loss ratio requirements (eCFR, current as of October 28, 2026); Social Security Act §1857(e)(4), 42 U.S.C. 1395w-27(e)(4).
    • An MA organization whose contract-level medical loss ratio is below 0.85 must remit total revenue times the difference; CMS bars new enrollment after three consecutive years below 0.85 and terminates the contract after five.
    • The ratio is tested by contract; no I-SNP-specific medical loss ratio is published.
    • 42 CFR 422.2420(b)(1)(iii) counts, in the numerator, expenditures for activities that improve health care quality as defined in 422.2430, and 422.2430(a)(4)(i) names "Medication Therapy Management Programs meeting the requirements of § 423.153(d)"; 422.2430(a)(2)(i) also names medication and care compliance initiatives and chronic disease management. Activities designed primarily to control or contain costs are excluded (422.2430(b)(1)). Whether a specific vendor cost qualifies is a question for your actuaries and counsel.
  9. Medicare Payment Advisory Commission. Mandated report: Dual-eligible special-needs plans. Chapter 15 in Report to the Congress: Medicare and the Health Care Delivery System. March 2026.
    • In July 2024, 46% of all dual-eligible beneficiaries (full- and partial-benefit; 5.378 million of 11.691 million) were enrolled in D-SNPs: coordination-only 27%, highly integrated 15%, fully integrated 3%. D-SNP plans numbered 539 in 2020, 903 in 2025 and 1,019 in 2026.
    • Table 15-1 (2022): average Medicare spending was $25,871 per dual-eligible beneficiary ($26,947 full-benefit, $22,831 partial-benefit) versus $11,834 for other Medicare beneficiaries, covering Parts A, B and D without premiums.
  10. Centers for Medicare & Medicaid Services. Medicare Program; Contract Year 2027 Policy and Technical Changes to the Medicare Advantage Program [proposed rule, CMS-4212-P]. 90 Federal Register 54894, November 28, 2025; request for information on C-SNP and I-SNP growth at 90 Federal Register 54978–54984. Centers for Medicare & Medicaid Services. Medicare Program; Contract Year 2027 and Certain Contract Year 2026 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, and Medicare Cost Plan Program [final rule]. 91 Federal Register 17384, April 6, 2026.
    • I-SNPs: 144 plans in contract year 2025 (139 in 2021, peak of 171 in 2023); enrollment 121,188 in 2025, up 39% from 87,037 in 2021; approximately 90% of enrollment is dually eligible each year.
    • The request for information asked for comment on a State Medicaid agency contract requirement for C-SNPs and I-SNPs with high (60% or more) dual enrollment, and on whether to extend D-SNP care-coordination or Model of Care requirements to C-SNPs and I-SNPs. The final rule adopted no policy from the request.
    • Final rule: Model of Care off-cycle revision windows for D-SNPs and I-SNPs are January 1 – March 31 and October 1 – December 31.
    • C-SNPs (proposed rule): 207 plans in contract year 2021 and 385 in 2025; enrollment 387,920 in 2021 and 1,103,194 in 2025; dually eligible C-SNP enrollees rose from 103,877 to 210,983 and C-SNPs with 60% or more dual enrollment from 16 to 66; C-SNPs and I-SNPs are currently exempt from the D-SNP look-alike limits at 42 CFR 422.514(d). The final rule adopted no policy from the request for information.
  11. Hung A, Wilson L, Smith VA, Pavon JM, Sloan CE, Hastings SN, Farley J, Maciejewski ML. Comprehensive medication review completion rates and disparities after Medicare Star Rating measure. JAMA Health Forum. 2024;5(5):e240807. doi:10.1001/jamahealthforum.2024.0807. PMID 38700854.
    • 561,950 community-dwelling Medicare beneficiaries aged 66 and older (5% claims linked to Part D MTM data, 2013–2020; nursing-home residents excluded). Comprehensive medication review completion by plan-defined eligibility rose from 10.2% (2013) to 35.8% (2020) while the plan-eligible pool fell by nearly half after 2015; with a consistent Medicare minimum eligibility threshold, completion rose from 4.4% to 12.6%. Dual-Medicaid enrollees had a greater post-2016 rise in completion (slope adjusted rate ratio 1.35, 95% CI 1.21–1.50, from the full text) but remained less likely to complete a review than beneficiaries with neither Medicaid nor the low-income subsidy. A June 2024 erratum corrected a figure.
    • Funded by the U.S. Deprescribing Research Network, the Durham Veterans Affairs medical center and Veterans Affairs Health Services Research and Development, and National Institute on Aging career awards. Observational; not specific to SNPs.
  12. Bousman CA, et al. Clinical Pharmacogenetics Implementation Consortium (CPIC) guideline for CYP2D6, CYP2C19, CYP2B6, SLC6A4, and HTR2A genotypes and serotonin reuptake inhibitor antidepressants. Clin Pharmacol Ther. 2023;114(1):51-68. doi:10.1002/cpt.2903; and the CPIC guideline list.
    • For CYP2C19 poor metabolizers taking citalopram or escitalopram (strong recommendation) or sertraline (moderate), consider an antidepressant not predominantly metabolized by CYP2C19; if citalopram or escitalopram is appropriate, consider a lower starting dose, slower titration and a 50% reduction of the standard maintenance dose.
    • CPIC guidelines are published for SSRIs (2023), tricyclics (2016), codeine and tramadol (2021), clopidogrel (2022), proton pump inhibitors (2020), statins (2022) and warfarin (2017). CPIC has rated CYP2D6 with risperidone, aripiprazole and haloperidol at level B or C but has published no guideline for them; a CYP2D6 antipsychotic review is listed as in progress (as of October 2026).
  13. Bain KT, Matos A, Knowlton CH, McGain D. Genetic variants and interactions from a pharmacist-led pharmacogenomics service for PACE. Pharmacogenomics. 2019;20(10):709-718. doi:10.2217/pgs-2019-0047
    • PHARM-GENOME-PACE study (NCT03257605): PGx testing of 100 PACE participants identified 146 genetic variants, 169 drug–gene interactions and 125 drug–drug–gene interactions, and 280 phenoconversion events (62.9% affecting CYP3A4). Descriptive, with interactions identified by a clinical decision support system and no clinical outcomes.
    • Co-authored by Calvin H. Knowlton, now ChorusRx's founder, at a prior company.
  14. Medicare Payment Advisory Commission. Medicare beneficiaries in nursing homes. Chapter 5 in Report to the Congress: Medicare and the Health Care Delivery System. June 2025.
    • In 2025, 32 insurers offered I-SNPs with about 122,000 enrollees (March data); I-SNPs covered about 12% of long-stay Medicare nursing-home residents in 2023. Market shares were currently around 50% for one national insurer, 40% for provider-sponsored plans and 10% for other insurer-sponsored plans.
    • In 2024, 23 of 31 insurers offering I-SNPs were provider-sponsored, with nursing homes holding an equity or ownership stake; nearly all insurers have fewer than 5,000 I-SNP enrollees and most fewer than 2,500. Interviewees gave minimum viable scale as anywhere from about 500 enrollees (in a joint venture) to several thousand; one said about 1,000 by year two or three.
    • Operating model: NPs typically visit participating nursing homes two to three times a week; NPs may be employed by the plan or the nursing home, or contracted. The most common facility payment is capitation plus incentive payments often tied to quality metrics and/or overall spending, typically upside-only shared savings; one nursing-home chain representative cited falls with major injury, polypharmacy and hospitalizations as examples.
    • Bids average 91% of benchmark for I-SNPs versus 77% for conventional MA and 79% for D-SNPs; rebates are 6% of benchmark versus 15% and 14%. MedPAC notes higher bids may indicate higher costs or less competitive pressure.
    • Literature judgment: I-SNPs reduce inpatient care use, with no clear positive or negative effect on other quality measures; HEDIS results (long-stay residents, measurement year 2023) were mixed: better on limiting harmful drug–disease interactions in dementia and limiting high-risk medications, with MedPAC noting this differs from its 2013 finding and it is unclear whether that reflects real improvement. The evidence base is "still somewhat limited." MedPAC cautions that nursing homes are not randomly assigned to participate and that selection and coding effects for I-SNPs were not estimated.
    • Table 5-16 (2025 data, per member per month, risk-adjusted): conventional MA bid 77% of benchmark with a rebate of 15% of benchmark; D-SNP 79% and 14%; I-SNP 91% and 6% (benchmark $3,035, bid $2,749 and payment $2,938 per member per month for I-SNPs). I-SNPs used 26% of their rebate dollars to lower Part D premiums (53% to supplemental benefits, 14% to cost sharing). MedPAC reports 88% of I-SNP enrollees were in plans with some quality bonus payment, 22% of them through the 3.5-point add-on for low-enrollment plans.
    • D-SNP bid $1,427 per member per month (benchmark $1,819, payment $1,685) and conventional MA bid $924 (2025). MedPAC publishes no dollar figure by plan type for C-SNPs or for 2026.
  15. Jarvis JP, Peter AP, Keogh M, Baldasare V, Beanland GM, Wilkerson ZT, Kradel S, Shaman JA. Real-world impact of a pharmacogenomics-enriched comprehensive medication management program. J Pers Med. 2022;12(3):421. doi:10.3390/jpm12030421
    • Retrospective difference-in-differences analysis of 5,288 Teachers' Retirement System of the State of Kentucky members aged 65+ who completed genetic testing and pharmacist consultation versus 22,357 non-enrollees, over 32 months.
    • 14.9% fewer inpatient events than expected (inpatient days −141.03 per 1,000, p=0.0008); 6.8% fewer emergency department visits (−34.41 per 1,000, p=0.0549, not significant at the paper's 0.05 threshold); $218.34 per member per month (PMPM) medical cost savings (p=0.0151). The enrolled group already differed at baseline (higher PMPM cost and medication count); voluntary enrollment; the program bundled PGx with pharmacist management, so PGx alone is not isolated.
    • Program delivered by Coriell Life Sciences; authors are affiliated with Coriell Life Sciences and the Know Your Rx Coalition.
    • Average medical charges to the plan per member per month, from the paper's Figure 3: intervention group $2,616.50 in the 2017 baseline year against $2,383.30 for the comparison group, and $3,079.50 against $3,297.60 in January to August 2020. The $218.34 is a difference-in-differences estimate (baseline gap $233.17 less the post-program gap); it excludes pharmacy claims. The paper reports no percent reduction in total cost. Our arithmetic: $218.34 is 8.3% of the intervention group's baseline cost, 9.2% of the comparison group's and about 6.8% of the cost the enrolled group would have run without the program, so we describe it as about 7% to 8%. Observational, unadjusted for selection into a voluntary program, and 2020 data include the early pandemic.
  16. Centers for Medicare & Medicaid Services. Special Needs Plan (SNP) Comprehensive Report, October 2026 (data from the Health Plan Management System), with the October 2025 report.
    • October 2026: 8,483,994 SNP enrollees in 1,800 plans, up 10.05% from 7,709,285 enrollees in 1,505 plans in October 2025. D-SNP 6,492,413 (1,082 plans; 76.5% of SNP enrollment; +4.9%); C-SNP 1,860,564 (562 plans; 21.9%; +33.8% from 1,390,869 in 391 plans); I-SNP 131,017 (156 plans; 1.5%; +2.6% from 127,675 in 165 plans).
    • Records with 1–10 enrollees are blanked at plan level and aggregated into one "Under-11" record per SNP type, which is included in these totals (122 enrollees in 70 plans in October 2026). Employer-only group plans are omitted from the report. Counts differ from KFF's (March) and MedPAC's (July) because of snapshot month and inclusion rules; we found no true conflict.
    • Our analysis of this report's plan-level I-SNP rows (October 2026): 156 plans averaging 840 members; among the 130 plans with a published count (26 plans with 1–10 members are suppressed), median 608 and 42% under 500. Summed by contract, 69 contracts have a published count: median 904 members (25th to 75th percentile 451 to 1,387), mean 1,898; 18 contracts (26%) under 500, 60 (87%) under 2,500 and 3 over 5,000. The largest contract holds about 35% of all I-SNP enrollees, which is why the mean runs well above the median.
    • The same analysis for D-SNPs (October 2026): 344 contracts with a published count, median 6,031 members (25th to 75th percentile 1,513 to 18,878), 90th percentile 45,175, mean 18,873; the median D-SNP plan has 2,153. For C-SNPs: 141 contracts, median 3,914 (25th to 75th percentile 1,228 to 12,427), 90th percentile 30,349, mean 13,195; the median C-SNP plan has 1,221.
  17. Centers for Medicare & Medicaid Services. Contract Year 2027 Part D Bidding Instructions; Social Security Act §1860D-11(b).
    • The statutory bid deadline is the first Monday in June (the CY2027 deadline was June 1, 2026). June 7, 2027 is the first Monday in June 2027 by the calendar; CMS had not yet published the CY2028 bid date when this page was prepared.
  18. Swen JJ, van der Wouden CH, Manson LEN, et al. A 12-gene pharmacogenetic panel to prevent adverse drug reactions: an open-label, multicentre, controlled, cluster-randomised crossover implementation study. Lancet. 2023;401(10374):347-356. doi:10.1016/S0140-6736(22)01841-4
    • 18 hospitals, 9 community health centres and 28 community pharmacies in 7 European countries; 6,944 adults aged 18+ (median age 58) starting a drug with a Dutch Pharmacogenetics Working Group guideline. Primary analysis (gatekeeping): among the 1,558 patients (25.2%) with an actionable variant for the index drug, clinically relevant adverse drug reactions within 12 weeks occurred in 21.0% genotype-guided versus 27.7% standard care, odds ratio 0.70 (95% CI 0.54–0.91, p=0.0075); across all patients 21.5% versus 28.6%, odds ratio 0.70 (0.61–0.79, p<0.0001).
    • Not nursing-home or older-adult specific; reactions were patient-reported; 97.7% of participants had European, Mediterranean or Middle Eastern ancestry; open-label.
  19. Elliott LS, Henderson JC, Neradilek MB, Moyer NA, Ashcraft KC, Thirumaran RK. Clinical impact of pharmacogenetic profiling with a clinical decision support tool in polypharmacy home health patients: a prospective pilot randomized controlled trial. PLoS One. 2017;12(2):e0170905. doi:10.1371/journal.pone.0170905
    • Open-label pilot randomized controlled trial at one home health agency, 110 patients (57 tested, 53 untested; mean age 75.6). Rehospitalizations per patient at 60 days: 0.33 versus 0.70 (rate ratio [RR] 0.48, 95% CI 0.27–0.82, p=0.007); at 30 days 0.25 versus 0.38 (RR 0.65, 0.32–1.28, p=0.21, not significant).
    • No power calculation, single site, no multiplicity adjustment; the intervention bundled testing, decision support and pharmacist recommendations; several authors work for the testing company.
  20. Jin H, Yang S, Bankes D, Finnel S, Turgeon J, Stein A. Evaluating the impact of medication risk mitigation services in medically complex older adults. Healthcare (Basel). 2022;10(3):551. doi:10.3390/healthcare10030551
    • Retrospective non-randomized analysis of 2,545 PACE participants across 19 organizations (12 using the service, 7 not), 2018–2019 claims. Year-over-year cost growth $4,386 per participant (95% CI $3,040–$5,732) with the service versus $9,410 ($7,737–$11,084) without; difference $5,024 (p<0.001), 75.8% from facility-related spending.
    • No statistically significant difference in adverse drug event rates. PGx was part of the service for organizations that chose it; its separate contribution was not measured.
    • All authors are employees and stockholders of Tabula Rasa HealthCare, the service's owner and funder; research conducted at CareKinesis/Tabula Rasa HealthCare, our founder Calvin H. Knowlton's prior company.
  21. Roncal-Belzunce V, Gutiérrez-Valencia M, Leache L, Saiz LC, Bell JS, Erviti J, Martínez-Velilla N. Systematic review and meta-analysis on the effectiveness of multidisciplinary interventions to address polypharmacy in community-dwelling older adults. Ageing Res Rev. 2024;98:102317. doi:10.1016/j.arr.2024.102317. PMID 38692414.
    • 17 randomized trials, 15 at high risk of bias; certainty low or very low for most outcomes. Medication appropriateness (odds ratio 0.39) and adherence (risk ratio 1.14) improved; no relevant benefit for the primary outcomes of functional and cognitive status, or for falls, mortality, quality of life, satisfaction, hospital admissions, emergency department visits or primary care visits.

Notes 20 and 13 come from research conducted at CareKinesis/Tabula Rasa HealthCare, our founder Calvin H. Knowlton's prior company, in the PACE population ChorusRx serves today; notes 15 and 19 describe programs run by other organizations whose authors include their developers. Results vary by plan. Program rules, payment policies and Star Ratings measure sets are set by CMS and change; verify all parameters against current CMS guidance.