posted by AHIP
on March 1, 2019
On March 1, 2019, AHIP submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS), responding to the 2020 Advance Notice and Draft Call Letter for Medicare Advantage and Part D Plans.
In our letter, we highlight CMS’ statements in the Advance Notice that the Medicare Advantage and Part D programs have demonstrated the value of private sector innovation and creativity, and that CMS is committed to “continuing to strengthen Medicare Advantage by promoting greater innovation, transparency, flexibility, and program simplification.” We highlight key CMS proposals that we support, including the provision addressing new benefit flexibility for chronically ill enrollees. In addition, we raise significant concerns with changes that would undermine the program’s ability to deliver affordability, stability, and choice for Medicare beneficiaries. They include, for example, significantly reduced risk scores, particularly for low-income enrollees, and failing to adjust county benchmark calculations as recommended by the Medicare Payment Advisory Commission.
To ensure that Medicare Advantage can continue to deliver value, we urge CMS to enhance its transparency and engage with stakeholders outside of the rate notice process in developing the risk model and in making other payment policy changes that have major implications for the benefit packages that Medicare Advantage plans can offer to enrollees.