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AHIP Submits Comments on 2024 Medicare Advantage Advance Rate Notice

Press Release

Published Mar 6, 2023 • by AHIP

WASHINGTON, D.C. – (March 6, 2023) – Today, AHIP submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the Advance Notice of Methodological Changes for Calendar Year 2024 for Medicare Advantage (MA) and Part D (Advance Notice).

“Our comment letter reiterates our serious concerns that CMS’ proposals would increase costs and reduce benefits in 2024 for tens of millions of seniors and people with disabilities,” said Matt Eyles, AHIP President and CEO. “It also brings forward new data and research that shows how these cuts will specifically and significantly impact Americans who are ‘dual eligibles’ and qualify for both Medicare and Medicaid. These lower-income enrollees are more likely to have multiple chronic illnesses and complex care needs. We remain focused on strengthening and improving Medicare Advantage and urge the Administration to pull back its flawed payment model revisions for 2024 and work with health insurance providers and other stakeholders to ensure MA is able to continue providing innovative, high-quality care to enrollees.”

New Study Illustrates Impact of Advance Rate Notice

The comment letter included the results of a study commissioned by AHIP from the Wakely Consulting Group. In its study, Wakely reviewed data from a broad range of MA plans and found that the proposed changes to the MA risk adjustment model would result in an average payment cut to MA of 3.7%. The Wakely study found even larger cuts to MA plans that serve dual eligibles; on average, the Advance Notice would cut payments for dual eligibles by 6.4%. The Wakely study also noted wide differences in results across MA plans and geographic areas.

AHIP is concerned that the policies in the Advance Notice would limit critical funding for supplemental benefits that may not be covered through Medicaid. This puts at risk the health of sicker, lower-income patients, many of whom live in historically underinvested or underrepresented communities and are more adversely affected by social drivers of health.

AHIP Comment Letter Highlights

Highlights from the AHIP comment letter include:

Medicare Advantage Works:

“…Americans agree that the Medicare Advantage (MA) and Part D programs are enormously successful models of public/private partnerships that offer choice, competition, and innovation. These programs deliver high-quality, affordable coverage and care to tens of millions of America’s seniors and people with disabilities.”

MA Provides Better Care, Better Value, and Better Outcomes:

“Compared to the original Medicare program, MA plans deliver coverage and care for a more diverse and vulnerable population, as more than half of individuals dually eligible for Medicare and Medicaid benefits are enrolled in MA. MA plans also provide better and more coordinated care, more comprehensive benefits, and better outcomes; increased financial security; are more cost effective; lead the way in value-based care; and earn greater satisfaction rates.”

The Advance Rate Notice Would Harm Vulnerable Enrollees:

“We believe the Advance Notice is inconsistent with national and CMS policy goals of advancing health equity, improving the health care delivery system, expanding the use of quality- and value-based payments, and enhancing care coordination and disease management. If finalized, the proposals would ultimately increase premiums and/or reduce benefits for tens of millions of seniors and people with disabilities in 2024—and in an especially meaningful way for some of the most medically vulnerable and low-income seniors enrolled in MA.”

Short Timeline and Overall Process Does Not Permit Meaningful Analysis and Feedback:

“Our most significant concern with the Advance Notice is the flawed revision to the proposed risk model for 2024…. it included an inadequate process for considering such a complex change and a failure to account for the disproportionate and potentially devastating impacts it would have on certain areas and populations, including individuals dually eligible for Medicare and Medicaid.”

Click here to view and download the letter.

Click here to view and download new research analyzing the impact of the Advance Rate Notice.

About AHIP

AHIP is the national association whose members provide health care coverage, services, and solutions to hundreds of millions of Americans every day. We are committed to market-based solutions and public-private partnerships that make health care better and coverage more affordable and accessible for everyone. Visit to learn how working together, we are Guiding Greater Health.