CMS Releases Proposal to Streamline Medicare Advantage and Part D

The Biden administration recently proposed a rule to simplify Medicare Advantage (MA) and Part D plan prior authorization and increase health equity requirements in star ratings. The Centers for Medicare & Medicaid Services (CMS) released a proposed rule for the 2024 coverage year, which includes provisions governing prior authorization, utilization management, and medical necessity determinations. The rule also limits MAOs' discretion to require the use of alternate services or settings and regulates the use of prior authorization. Additionally, CMS seeks to establish a utilization management committee and require relevant expertise for coverage determinations. The proposals are in response to concerns raised by the Office of Inspector General and Congress regarding prior authorization and aim to address the administrative burden for doctors while cracking down on misleading marketing. Overall, the proposed rule strives to improve healthcare access and quality for Medicare beneficiaries.

The proposed rule also includes a provision to add health equity requirements to the MA and Part D star ratings. CMS proposes to add a new measure to the star ratings that assesses whether a plan has taken steps to reduce disparities in healthcare outcomes and experiences among enrollees based on race, ethnicity, and other socio-economic factors. The proposed measure would be used in the calculation of the overall star rating and would incentivize plans to prioritize health equity in their operations and strategies.

In addition, the proposed rule implements several drug price provisions of the Inflation Reduction Act, including requiring drug manufacturers to provide rebates to Part D plans for price increases that exceed inflation and capping the amount that beneficiaries pay for insulin at $35 per month.

Overall, the proposed rule seeks to address some of the key challenges faced by Medicare Advantage and Part D plans, including prior authorization and health equity, while also implementing provisions to reduce drug prices and improve access to care for beneficiaries. The proposal is open for public comment until February 14, 2023, and CMS is expected to release a final rule later in the year.

Payment Year 2015 Risk Score Rerun & Over-payment Recovery

Payment Year 2015 Risk Score Rerun & Over-payment Recovery

Deadline to submit all PY 2015 (2014 dates of service) deletions to the Risk Adjustment Processing System (RAPS) is 8:00 PM EDT, Thursday, June 7, 2018.

  • All RAPS deletions received by the deadline will be included in the risk score rerun and subsequent overpayment recovery.

  • This rerun will also include updated Phase III v 3 filtering code for the diagnoses from encounter data.

  • MARx payment adjustments as a result of this risk score run will be identified on the Monthly Membership Data File (MMDF) by the Adjustment Reason Code (ARC) 25 – Part C Risk Adjustment Factor Change/Recon and ARC 37 – Part D Risk Adjustment Factor Change.

MA Risk Adjustment Data Submission Deadlines

MA Risk Adjustment Data Submission Deadlines

Annual Run Memo (2018-2020 initial, mid-year, final)

  • For Payment Year 2018, CMS will apply the blended risk score -- 15% of the risk score calculated with diagnoses from encounter data and FFS claims summed with 85% of the risk score calculated with diagnoses from RAPS and FFS claims – for the mid - year PY 2018 risk scores, as well as when CMS calculates the final PY 2018 risk scores.

  • For Payment Year 2019, CMS will apply the blended risk score – 25% of the risk score calculated with diagnoses from encounter data, FFS claims, and RAPS inpatient records summed with 75% of the risk score calculated with diagnoses from RAPS and FFS -- when they calculate the initial PY 2019 risk scores, and will continue to do so for mid - year and final risk scores.

Impact Of The Transition From RAPS To EDS On Medicare Advantage Risk Scores

Impact Of The Transition From RAPS To EDS On Medicare Advantage Risk Scores

A Milliman study of the transition from RAPS to EDS found there to be a -4% difference in the median percentage difference between PY 2016 risk scores. The percentage difference is larger for special needs plans (SNPs) and smaller for general enrollment plans.

This results in a reduction of approximately $40 per member per year.

New CMS Information On EDS Risk Scores

New CMS Information On EDS Risk Scores

The December 29, 2016, memo from CMS announced two changes to the data submission and risk score calculation schedules that were previously released:

1. Submission deadline for EDS data has been extended for the 2016 final risk scores

2. 2017 mid-year risk s core updates will be based only on RAPS