On January 30, the Centers for Medicare and Medicaid Services (CMS) published a
request for information (RFI) seeking feedback from broad perspectives on Medicare Advantage (MA) data currently collected and not collected, including format that will provide better transparency into MA organizations and their operations. The goal of the RFI is to make MA data commensurate with traditional Medicare for transparency and comparison to other programs such as ACOs and other programs. This RFI is an extension of the previously issued general RFI in August 2022 which received over 4,000 responses. Themes in that response included the need for stronger beneficiary protections, payment issues, and programmatic data.
Topics of interest include:
- Beneficiary access to care, including provider directories and networks
- Prior authorization and utilization management, including denials of care and beneficiary experience with appeals processes as well as use and reliance on algorithms
- Cost and utilization of supplemental benefits
- MA marketing and consumer decision-making
- Care quality and outcomes, including value-based care arrangements and health equity
- Healthy competition in the market, including the impact of mergers and acquisitions, high levels of enrollment concentration, and the effects of vertical integration
- Special populations such as individuals dually eligible for Medicare and Medicaid, end stage renal disease (ESRD), and other enrollees with complex conditions
Comments are due May 29, 2024. AHCA will be working through the Reimbursement Committee and PHM Council to offer comments.
CMS notes that if the policies are finalized as proposed, MA payments are expected to increase by 3.7 percent (over $16 billion) from 2024 to 2025. The proposed rate includes an MA risk score trend of 3.86%. It also includes year two of the three-year phase-in of several technical and clinical updates to the MA risk adjustment model and medical education costs.
CMS is also proposing improvements to Part D drug benefit for CY 2025 that will result in lower costs for beneficiaries.
Comments to the proposed rule are due to CMS by March 1, 2024. AHCA is analyzing the rule from via the PHM Council and offering comments.
Rate Announcement and Part D Redesign Program Instructions must be released by April 1, 2024.