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Care for Older Adults: Medication Review (COA-M) and Functional Status Assessment (COA-F)

Two HEDIS indicators reported for members 66 and older enrolled in Special Needs Plans (SNPs). Each reports the percentage of members who received the service at least once during the measurement year, and each is rated as a separate Part C Star measure.

Measure steward

NCQA

Population

SNP members 66+

Weighting category

Process

2027 Star weight

1 each

Direction

Higher is better

Period

Calendar year

Specification

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	Medication Review (COA-M)	Functional Status Assessment (COA-F)
Denominator	Members 66 and older as of December 31, enrolled in a Special Needs Plan.
Numerator	Both of the following: a dated, signed medication review by a provider with prescribing authority or a clinical pharmacist, and a medication list with a dated notation in the same medical record, coded on the same date of service. A transitional care management service also meets the numerator.	At least one complete, dated functional status assessment documenting one of: ADLs assessed, or at least five of bathing, dressing, eating, transferring, toileting, and walking; IADLs assessed, or at least four of shopping, transportation, telephone use, meal preparation, housework, home repair, laundry, taking medications, and handling finances; or the result of a standardized functional status tool. Components may be completed at separate visits within the year.
Does not count	A review of side effects for a single medication at the time of prescribing; medication lists or reviews done in an acute inpatient setting.	An assessment limited to an acute or single condition, event, or body system, such as a knee after a fall; assessments done in an acute inpatient setting.
Exclusions	Hospice; members who died during the measurement year.
Delivery	In person or by telehealth, including audio-only visits and virtual check-ins. Neither an outpatient visit nor the member's presence is required. If the member takes no medications, document that.	In person or by telehealth, including audio-only visits, e-visits, and virtual check-ins.
Common codes	CPT II 1159F (medication list) with 1160F (medication review) on the same date of service; TCM 99495 or 99496.	CPT II 1170F (functional status assessed).

Both indicators accept supplemental data. COA-F returned to the Star Ratings for 2027 after a substantive specification change.

What closes the gap

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Scenario	COA-M	COA-F
Annual wellness visit with a reconciled medication list, a documented review, and a standardized ADL tool	Compliant	Compliant
Clinical pharmacist review by telephone, with the reviewed list documented in the medical record and coded	Compliant	Not addressed
Health risk assessment that documents ADLs, submitted as supplemental data	Not addressed	Compliant
Post-discharge TCM visit	Compliant	Only if a complete assessment is documented
Medication list updated by staff, no documented review by a prescriber or pharmacist	Not compliant	Not addressed
Orthopedic visit assessing knee function after a fall	Not addressed	Not compliant
Medication reconciliation during a hospital stay	Not compliant	Not addressed

Clinical and operational considerations

COA-M is topped out. Contract performance is high and tightly clustered, which is why CMS cited low variation in removing it. A small miss can still cost a star while it remains rated.
Both elements must be on the same visit. A list without a documented review, or a review without the list, does not count.
Clinical pharmacists qualify for COA-M, by phone. Audio-only reviews count and the member does not need to be present, so pharmacist-led reviews can close the gap when the review and list are documented and coded.
COA-F needs a whole-person assessment. Condition-specific function, such as gait after a hip fracture, does not meet the specification.
The annual wellness visit and the HRA are natural homes. AWV templates can capture both indicators at once, and an HRA that documents ADLs can satisfy COA-F, though it does not cover the medication review.
Supplemental data matters. Both indicators are documentation-driven, so CPT II coding and timely supplemental data submission determine whether completed work is counted.

Policy watch

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	Change
2027 Star Ratings (MY2025)	COA-M rated at weight 1. COA-F returns as a new measure at weight 1 after a substantive specification change, so its cut points have no guardrail in the first year. COA Pain Assessment was removed following NCQA's retirement of the indicator.
2029 Star Ratings (MY2027)	Final rule summaries list COA-M among the 11 measures removed, citing low variation. Confirm COA-F's status for MY2027 in CMS guidance; some industry calendars list it for retirement as well.
Digital transition	NCQA is moving COA to ECDS reporting as it phases out the hybrid method by MY2029.

References

CMS. 2027 Star Ratings Measures and Weights.
National Committee for Quality Assurance. HEDIS Volume 2: Care for Older Adults (COA).
CMS. Contract Year 2027 Medicare Advantage and Part D Final Rule (CMS-4208-F3), April 2, 2026.
NCQA. Proposed timeline for retiring and replacing HEDIS hybrid measures.

Specifications are summarized for education. Consult the PQA measure specifications and CMS Star Ratings Technical Notes for the measurement year in question. Prepared by the MedWatchers clinical pharmacy team, October 2026.