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AHIP Submits Comments on Proposed Rule on Medicare Advantage Policy and Technical Changes for 2024

Press Release

Published Feb 14, 2023 • by AHIP

Washington, D.C. – (February 14, 2023) – AHIP submitted its comments to the Centers for Medicare & Medicaid Services (CMS) regarding its Proposed Rule for policy and technical changes to the Medicare Advantage and Part D programs for contract year 2024.

Matt Eyles, President and CEO of AHIP, noted that changes put forward in this proposed rule must be evaluated in the context of broader, sweeping changes being proposed to the MA program, including the 2024 Advance Notice:

“More than 30 million seniors and people with disabilities choose Medicare Advantage (MA) because it delivers better services, better access to care, and better value. For years, MA has been an example of a public-private partnership that works for American patients, consumers, and taxpayers.

“The Proposed Rule is just one of many proposed regulatory changes that are introducing new uncertainties and risk into the MA program. We are particularly very concerned about changes proposed by the Advance Rate Notice, which would result in billions of dollars of cuts to the MA program, leading to higher premiums and fewer benefits for enrollees. We encourage CMS to work together with other partners to ensure that seniors and people disabilities can continue to benefit from the improved health and financial security that MA offers them.”

Here are the highlights from AHIP’s comment letter on the Proposed Rule:

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

“To build on these successes, AHIP supports a number of proposals that would strengthen consumer protections while retaining flexibility, choice, competition, and value. At the same time, we are concerned that certain proposals would reduce funding or increase costs without benefiting seniors and people with disabilities.”

For example, we have serious concerns with proposed changes to the Star Ratings program, including proposals to eliminate the reward factor and limit application of the hold harmless policy for the improvement measures, which would make it more difficult for MA plans to obtain funds to offer more choices, expand supplemental benefits, and keep premiums low. We are also concerned that implementation of Inflation Reduction Act (IRA) changes in Part D could further negatively affect certain Star Ratings measures and plan performance due to factors outside of plan control. While we appreciate CMS proposing to decrease the weight of survey measures relative to the weight of clinical outcome measures as AHIP has previously recommended, the overall impact of the Star Ratings proposals would be higher premiums and/or reduced benefits for enrollees, impacts that would disproportionately affect seniors and people with disabilities in underserved communities without increasing quality.

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.