AHIP has retained Wakely Consulting Group LLC. (Wakely) to provide a financial impact summary report of the information presented in the Notice.
Key highlights of our analysis are:
- The CY2024 fee-for-service (FFS) growth rate is lower than projections from the 2023 Final Announcement. A portion of the downward restatement is driven by a technical change. CMS has not commented on the additional drivers.
- The proposed Part C risk adjustment model is expected to decrease plan risk adjusted payment by 3.7% overall. The impacts vary significantly by model segment and geographic region, and for individual plans.
- The proposed FFS normalization factor excludes PY2021 risk scores in the calculation of the underlying trend. The exclusion of PY2021 increases the FFS normalization factor which decreases PY2024 risk scores.