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CMS Releases Advance Notice and Call Letter for Medicare Advantage and Part D

Late last week, CMS released the Advance Notice of Methodological Changes for Calendar Year (CY) 2019 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2019 draft Call Letter (Advance Notice and Call Letter). The Advance Notice and Call Letter should be read hand-in-hand with the Advance Notice of Methodological Changes for Calendar Year (CY) 2019 for the Medicare Advantage (MA) CMS-HCC Risk Adjustment Model (2019 MA Risk Adjustment Changes) that CMS released on December 27, 2017.  Both documents request comments from interested parties and have a submission deadline of March 5, 2018.

Among other issues, the 2019 MA Risk Adjustment Changes discusses the data to use for calculating risk scores in 2019 and proposes changes to hierarchical condition categories (HCCs) that are linked to increased risk scores. The Advance Notice and Call Letter covers many policy topics.  Some of the issues discussed in the Advance Notice and Call Letter include:

  • Updates to MA EGWP payment calculation;
  • Methodologies to establish the MA coding pattern adjustment;
  • The use of encounter data for risk adjustment in MA and Part D;
  • Collecting information from Medicare Advantage Organizations that is needed to operationalize certain evaluations and payments under MACRA;
  • Enhancements to Star Ratings;
  • Tagging plans with civil monetary penalties (CMPs) with an icon on Plan Finder;
  • Expanding the definition of health related supplement benefits that MA plans can offer beneficiaries;
  • Allowing MA plans to offer beneficiary rewards and incentives for completing a Health Risk Assessment;
  • Utilization review controls that Part D plans can use to address opioid abuse; and
  • CMS's interest in receiving information regarding potential modifications to the Part D mail-order refill consent policy.

We will be highlighting some key issues in both the 2019 MA Risk Adjustment Changes and the Advance Notice and Call Letter in posts in the coming weeks.

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Tara Swenson Dwyer is a Mintz attorney who advises private and public health care clients on mergers and acquisitions, joint ventures, and complex service arrangements. She works with managed care organizations, pharmaceutical services providers, and integrated delivery systems.