From Assessment to Action: Using Your HRA to Meet the New Depression Screening Requirement

The April 2026 CMS Final Rule removed 11 measures from Medicare Advantage Star Ratings, most of them from the administrative domain. What replaced them in terms of weight and importance are clinical outcomes, behavioral health, medication adherence, and member experience. These are not measures plans can influence through internal process improvements alone. They require member action, sustained over time.

Health plans are now asking the right question: what tools do we have that can actually move the needle on these measures? The Health Risk Assessment is one of the most direct answers to that question, and one of the most underutilized.

The HRA is not just a compliance checkbox or a data collection exercise. In the current Stars environment, a well-deployed HRA serves as the front end of a clinical pipeline: identifying risk, surfacing behavioral health flags, feeding care management workflows, supporting gap closure, and creating the longitudinal member relationship that the new measure set demands.

What the Final Rule Actually Changed

The April 2, 2026 CMS Final Rule finalized changes that take effect in measurement year 2027 and will be reflected in 2029 Star Ratings. The core shift: with the removal of high-performing administrative measures, clinical measures including HEDIS and pharmacy combined approach nearly half of the overall Star Ratings calculation by 2029, according to CMS. Survey measures, CAHPS and HOS together, will account for nearly 40% of total Star weight by the same year.

The practical effect is that plans have less margin for error. A single-weighted measure now represents a materially larger share of the overall score than it did before. High performance on any one domain no longer buffers drops elsewhere. Plans that built strong Star Ratings on the back of administrative measure performance are starting from a reset.

At the same time, CMS added a new behavioral health measure. The DSF-E (Depression Screening and Follow-Up for Adolescents and Adults) measure requires plans to screen members for clinical depression using a validated standardized instrument and, if the screen is positive, ensure a follow-up care encounter within 30 days. This is the first behavioral health measure in Medicare Advantage Star Ratings, and CMS has signaled it is not the last.

The HRA as a Clinical Data Engine

In the original Stars model, the HRA was valuable primarily as a participation measure and an NCQA compliance tool. In the new model, it serves a more active function. The data collected through the HRA directly supports the clinical and behavioral health measures that now carry the most weight.

PDHI's NCQA-certified Health Risk Assessment is built to do exactly this. It collects clinical, behavioral, and social determinants of health data in a single member-facing interaction, and it integrates that data with care management platforms, EHR systems, and analytics tools so that the right teams can act on it.

Key data the HRA captures that connects directly to Stars measures:

• Behavioral health screening: PHQ-2 for depression (relevant to DSF-E measure readiness)
• Chronic condition risk indicators: relevant to HEDIS measures for diabetes, hypertension, and cholesterol management
• Functional status and fall risk indicators: relevant to HOS Improving or Maintaining Physical Health and Reducing the Risk of Falling measures
• Medication adherence barriers: relevant to Part D adherence measures returning to triple weight
• Social determinants of health: SDOH data that informs care management targeting and intervention design

When the HRA is connected to downstream systems, each completed assessment generates a set of actionable signals that care management teams can use to close gaps, initiate outreach, and direct members to the right interventions. That is the HRA functioning as a clinical data engine, not just a survey.

The DSF-E Measure: The HRA as a Screening Gateway

The DSF-E measure is where the HRA-to-care-management workflow becomes most directly relevant to Stars compliance. Plans have less than six months before the measure takes effect and need to inventory their existing member touchpoints for depression screening coverage now.

PDHI's HRA includes the PHQ-2, a validated two-question short-form screening instrument for depression. The PHQ-2 is the appropriate tool for population-level screening in a self-administered digital assessment.

The PHQ-2 in the HRA functions as a screening gateway. When a member scores positive on the PHQ-2, that result exports to care management as a trigger for follow-up. The care management team then conducts the full PHQ-9 by phone. This two-step workflow allows the plan to:

• Screen at population scale through a digital, low-burden member interaction
• Route positive screens to the appropriate clinical team without delay
• Document the follow-up encounter required for DSF-E numerator compliance
• Capture the data in a HEDIS-compliant format through the care management system

Plans that do not yet have a PHQ-2 or equivalent validated instrument in their HRA, or that lack a defined care management workflow for positive screens, should treat DSF-E readiness as an immediate priority.

The HRA and Longitudinal Engagement

The measures that remain in Stars after the 2026 Final Rule share a common characteristic: they require sustained member behavior change, not one-time transactions. Medication adherence, chronic condition management, functional health improvement, depression screening and follow-up. These outcomes are built over time, through repeated touchpoints and care coordination that meets members where they are.

The HRA is the starting point of that longitudinal relationship. It is the interaction through which the plan learns what a member's risk profile looks like, what barriers they face, and what interventions are likely to be relevant to them. That information drives personalization of outreach, incentive design, action plan assignment, and coaching referrals.

Health plan leaders working with high-retention member engagement programs consistently identify a few factors that sustain engagement over time:

• Low burden of entry: the initial interaction needs to be easy to complete
• Personalization based on actual health data, not generic messaging
• Incentives connected to daily habits, not one-time events
• Care recommendations and action plans that reflect the member's real clinical situation

The HRA provides the data foundation for all of these. A member who completes the HRA and receives a personalized risk profile, targeted program recommendations, and an incentive for completing the assessment is already engaged in a different kind of relationship with their plan than one who receives a generic mailer.

What Plans Should Be Doing Now

Plans that have not yet connected HRA data to Stars strategy in a systematic way should start with an audit of the current state. Key questions:

• Does your HRA include a validated depression screening instrument such as the PHQ-2?
• Are HRA results transmitted to care management in a timely, usable format?
• Is there a defined workflow for members who screen positive on behavioral health questions?
• Are HRA risk indicators being used to identify HOS-relevant populations 12 to 18 months in advance of the survey?
• Are HRA results being used to drive personalized program recommendations, action plans, and incentives?
• Is HRA completion tracked and reported in a way that connects to HEDIS gap closure and Stars performance?

For DSF-E specifically, with less than six months before the measure takes effect, the immediate priority is ensuring PHQ-2 screening is in place, that positive results flow to care management, and that follow-up encounters are being documented in a HEDIS-compliant format.

For HOS, the work is longer-lead. Plans should be pulling HRA data now to identify members at risk for functional decline and building the cross-functional care management, behavioral health, and provider partnerships that are required to move HOS scores over time.

How PDHI Supports This Work

PDHI's NCQA-certified Health Risk Assessment is built for health plans operating across Medicare, Medicaid, and Commercial lines of business. It includes population-specific versions with age-appropriate screening, chronic condition focus, functional status assessment, SDOH data collection, and behavioral health screening including the PHQ-2.

HRA results flow to care management platforms, EHR systems, and analytics tools through PDHI's integration framework, ensuring that the data collected through the assessment reaches the teams responsible for acting on it. PDHI's incentive management capabilities support gap closure activities aligned with HEDIS measures and Stars performance, and its member engagement platform supports the longitudinal relationship that the new Stars measure set requires.

Plans using PDHI's NCQA-certified health assessment and self-management tools receive automatic credit for NCQA Population Health Management elements, reducing accreditation burden while meeting CMS quality requirements.

To learn more, visit pdhi.com or contact us at info@pdhi.com