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What the Clover STARs Lawsuit Means for Risk Adjustment Workflows

A recent court ruling in Clover Insurance Company v. HHS has put the Medicare Advantage STAR Ratings program under a much brighter spotlight. On May 27, 2026, the U.S. District Court for the Southern District of Georgia ruled that CMS improperly included 20 measures in Clover’s 2026 Star Rating calculation and ordered CMS to recalculate Clover’s rating. Public reporting around the case also notes that Clover argued the half-star difference at issue was worth roughly $120 million in bonus and related funding.

For risk adjustment teams, the question is not just what the case means legally. It is what the case means operationally. CMS’s 2027 final rule still moves the STAR Ratings program toward fewer administrative measures and greater emphasis on clinical quality, outcomes, and patient experience, including a new Depression Screening and Follow-Up measure beginning with the 2027 measurement year for 2029 STARs.

That means the core workflow pressure on plans and providers is still moving closer to the encounter, not farther away. Even if the legal dispute is about STAR Ratings methodology, the broader operating reality has not changed: quality, documentation, provider workflow, and payment integrity are now tightly connected.

What happened in the Clover STARs lawsuit?

Clover challenged its 2026 Medicare Advantage STAR Rating, arguing that CMS relied on measures that were not lawfully included in the calculation. The court agreed on two key points: that CMS exceeded statutory data-source limits for certain measures and that CMS failed to use required notice-and-comment rulemaking for others. Those findings were enough for the court to set aside Clover’s 2026 STAR Rating and require recalculation.

That distinction matters. This is not a signal that quality performance suddenly matters less. It is a signal that measurement methodology can be challenged when the legal basis is weak. Operationally, plans still need documentation, care-gap execution, and provider workflows that hold up whether scrutiny comes from STAR ratings oversight, internal performance review, or RADV-related documentation questions.

Why does a STARs lawsuit matter to risk adjustment teams?

It matters because STAR ratings and risk adjustment no longer live in separate operational lanes. CMS’s 2027 final rule streamlines STAR Ratings by removing several administrative or low-variation measures and increasing the relative importance of clinical outcomes and patient experience. In practice, that means more performance pressure lands inside provider workflows, where documentation quality, care-gap closure, and diagnosis support all intersect.

That is the same environment risk adjustment teams are already navigating. If a diagnosis is documented weakly, risk adjustment suffers. If follow-up care, screenings, and structured clinical actions do not occur reliably in the workflow, quality performance suffers. The workflow problem is shared, even if the regulatory programs are different.

For a broader take on that convergence, see:
Quality + Risk Adjustment: The Operational Marriage No One Can Avoid
How to Operationalize Risk Adjustment Across Clinical Workflows

What should plans not get wrong about this ruling?

Plans should not mistake legal uncertainty for operational relief. The Clover ruling may create important questions about how CMS structured certain STAR Ratings measures, but it does not change the fact that CMS is still pushing the program toward measures that better reflect real clinical quality and patient experience. Nor does it reduce the need for point-of-care documentation, defensible diagnosis support, or tighter provider workflow execution.

If anything, the right takeaway is the opposite: when methodology is under scrutiny, execution becomes more important. Plans need workflows that can withstand changing measure structures, not workflows that only work when the rules stay static.

Related reads:
From Retrospective to Prospective: Modernizing Risk Adjustment Workflows

Building an Audit-Ready Documentation Culture: From Reactive to Proactive

How does this affect provider workflows?

Provider workflows are where this becomes real. CMS’s 2027 final rule adds the new Part C Depression Screening and Follow-Up measure beginning with the 2027 measurement year for 2029 STARs, and the program overall is shifting weight toward more clinically meaningful measures.

For providers, that creates a familiar tension: more has to happen inside the encounter, but nobody wants to add more clicks, more alerts, or more friction. That is why the right response is not “do more documentation.” It is “build better workflows.” The same encounter should support quality performance, risk adjustment accuracy, and defensible documentation wherever possible.

If you want to see how that plays out in practice, read:
Combatting Data Fatigue: Turning FHIR Streams into Actionable Huddles

How Point-of-Care AI Improves RAF Accuracy Without Slowing Providers Down

How should plans respond right now?

The smartest response is operational, not reactive. Plans should start by separating the legal question from the workflow question. The legal question is whether CMS’s methodology in this case will hold up or need revision. The workflow question is whether providers, quality teams, and risk adjustment teams are already working from a model that is too retrospective, too fragmented, or too dependent on after-the-fact correction.

A practical response looks like this:

  • Audit where quality and risk adjustment already overlap in provider workflows
  • Measure how much work still depends on chart chase, provider queries, or retrospective cleanup
  • Identify which measures and diagnoses require stronger structured capture at the point of care
  • Improve provider-facing decision support so care-gap closure and diagnosis support happen earlier
  • Strengthen documentation defensibility before submission, not during remediation

That same logic carries into audit readiness. For that angle, see:
Preparing for RADV Audits: Building a Defensible Documentation Strategy

Building a Defensible Risk Adjustment Program in a Post-V28 Environment

What results should organizations expect if they respond the right way?

Organizations that treat this lawsuit as a workflow signal rather than just a legal headline should expect stronger coordination between quality and risk teams, lower retrospective burden, better point-of-care documentation, and more resilient performance across both STARs and risk adjustment. That does not mean the lawsuit itself changes those outcomes directly. It means the lawsuit highlights how costly fragmented workflows have become.

FAQs

What did Clover win in its STAR Ratings lawsuit?

Clover won a court order requiring CMS to set aside and recalculate its 2026 STAR rating after the court found problems with 20 measures used in the calculation.

Does the Clover ruling change risk adjustment requirements?

No. The Clover ruling is aboutSTAR Ratings methodology, but it does not reduce the need for stronger documentation, encounter-based workflows, or audit-ready diagnosis support.

Why does a STAR Ratings lawsuit matter to provider workflows?

It matters because STARs and risk adjustment now depend increasingly on the same provider-facing workflows, especially where documentation, care-gap closure, and clinical execution intersect.

What should plans do now?

Plans should keep strengthening point-of-care workflows, reduce reliance on retrospective fixes, and align quality and risk operations more closely.

Conclusion

The Clover case matters. But for most organizations, its greatest importance is not as a litigation headline. It is as an operational signal. Legal uncertainty around measure methodology does not change the fact that quality and risk adjustment are converging in the provider workflow. Plans that use this moment to improve point-of-care execution will be better positioned regardless of how the litigation evolves.

Contact Inferscience to learn how to strengthen the provider workflows that support your risk adjustment strategies and related STARs performance measures.

Sources

  1. Crowell & Moring — Clover Insurance v. HHS: S.D. of Georgia Holds 20 STAR Ratings Measures Unlawful
    https://www.crowell.com/en/insights/client-alerts/clover-insurance-v-hhs-sd-of-georgia-holds-20-star-ratings-measures-unlawful
  2. Modern Healthcare — Clover Health Medicare Advantage STAR Ratings Lawsuit
    https://www.modernhealthcare.com/insurance/mh-clover-health-medicare-advantage-star-ratings-lawsuit/
  3. Georgetown Law O’Neill Institute Litigation Tracker — Clover Insurance Company v. Department of Health and Human Services et al.
    https://litigationtracker.law.georgetown.edu/litigation/clover-insurance-company-v-department-of-health-and-human-services-et-al/
  4. CMS — Contract Year 2027 Medicare Advantage and Part D Final Rule
    https://www.cms.gov/newsroom/fact-sheets/contract-year-2027-medicare-advantage-part-d-final-rule
  5. CMS — Medicare Beneficiaries to See Simpler and More Flexible Plan Choices, Better Drug Coverage, Higher Quality
    https://www.cms.gov/newsroom/press-releases/medicare-beneficiaries-see-simpler-more-flexible-plan-choices-better-drug-coverage-higher-quality