Payer organizations respond to CMS' Medicare Advantage, Part D proposed rule

America's Health Insurance Plans and the Alliance of Community Health Plans have commented on the proposed 2023 changes to Medicare Advantage and Part D programs. 

CMS pitched the changes in early February and invited organizations to submit feedback. The two payer industry groups responded in a March news release and a letter

AHIP said it supports the regulatory efforts to improve the programs, including increasing integration of dual-eligible special needs plans and clarifying policies to customers to improve their experience.

ACHP also said it supports several policies, including the continued application of the statutory minimum of 5.90 percent coding pattern adjustment and CMS studying and eventually implementing end-stage renal disease rates at a smaller geographic level than the state level.

Both organizations took issue with proposed changes as well: 

  • AHIP recommends withdrawing the point-of-sale pharmacy price concessions proposal. In its letter, it states: "The proposal to require all possible pharmacy price concessions be included in a Part D plan's point-of-sale 'negotiated price' would not address the cause of out-of-control drug prices and result in higher Part D premiums for seniors and fewer $0 premium MA-PD plans for enrollees in Medicare Advantage."

  • AHIP also advised that CMS revise its Medicare Advantage star ratings to account for the effects of COVID-19. The ACHP argued for several changes to star ratings calculations, including ending the use of improvement measures.

  • They also argued for better alternatives on maximum out-of-pocket limit calculations in order to prohibit potentially significant increases in premium costs and/or limitation of available supplemental benefits to beneficiaries.

  • While the ACHP supports the CMS goal to better incentivize the collection of health equity data, it encourages a more gradual approach to give member plans time to organize their strategies.

  • The ACHP also recommends that CMS eliminate Part A-only and Part B-only beneficiaries' fee-for-service costs for establishing county benchmarks to take into account only those who are eligible for Medicare Advantage.


Read the news release and letter here and here.

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