CMS has slowly but surely been providing additional guidance to Medicare Plans (Medicare Advantage and Part D plans) regarding steps they can and should take to address the opioid epidemic as it relates to their beneficiaries. CMS’s most recent guidance to Plans regarding the opioid epidemic was included in the Advance Notice and Call Letter.

In November of 2017, in the proposed Medicare Advantage and Part D regulations for CY 2019 CMS set out a framework for Part D plans to monitor and reduce the potential misuse of prescription opioids. Continue Reading CMS’s Advance Notice and Call Letter: How Medicare Plans Can Report, Identify, and Address the Opioid Epidemic

Earlier this month, the Centers for Medicare & Medicaid Services (CMS) released its 2018 Medicare Advantage and Part D Advance Notice and Draft Call Letter (“Draft Call Letter”).  For the majority of the letter’s provisions, CMS is proposing to continue its current course of action and is refraining from introducing new policies.  With that said, however, CMS is proposing several notable updates, including updates to the use of encounter data for risk adjustment and the 2018 Star Ratings.  This blog is to highlight some key provisions and changes as MA and Part D plans prepare and finalize comments.

Continue Reading CMS’s Draft 2018 Call Letter: Minor Updates, but Largely a Continuation of Current Policies

Last week, the Centers for Medicare & Medicaid Services (CMS) released its 2017 Advance Rate Notice and draft Call Letter (“2017 Draft Call Letter”) for the Medicare Advantage (“MA”) and Part D programs.  With the final 2017 Call Letter to be released April 4, 2015, CMS is providing interested stakeholders until this Friday, March 4th to provide comments.

The 2017 Call Letter proposes a variety of updates to the program, many that are designed to improve the accuracy of payments to plans serving beneficiaries dually eligible for Medicare and Medicaid (“dual eligibles”).  Of note, CMS proposes updates to the risk adjustment model used to calculate payments to MA plans and to the Star Rating system used to evaluate plan performance.  CMS stated that these proposed changes reflect the public comments received when it shared research findings on the accuracy of the CMS-HCC model for paying dual eligible beneficiaries and the impact of socioeconomic factors on the Star Ratings and solicited input.  A few of the interesting 2017 proposals include: Continue Reading CMS Releases 2017 Advance Notice and Draft Call Letter

For the last of our series on the 2016 Draft Call Letter, we focus on the provisions impacting plans serving Medicare-Medicaid, or dual eligible, enrollees. As we have previously posted, the Centers for Medicare & Medicaid Services (CMS) has struggled with how to provide high quality, seamless care to dual eligible individuals. Through the 2016 Draft Call Letter, CMS further attempts to ease administrative burdens and provide incentives for plans to better integrate Medicare and Medicaid services. Specifically, the 2016 Draft Call Letter i) proposes changes to the Star Ratings program to reduce the weight of certain measures whose outcome may be impacted by dual status; ii) introduces a potential integrated Star Ratings system for Medicare-Medicaid Plans (MMPs); and iii) requests comments on providing certain administrative flexibilities to allow Dual Eligible Special Needs Plans (D-SNPs) to better integrate services. The Draft Call Letter also provides the annual updates to Low Income Subsidy (LIS) costsharing amounts and the Fully Integrated Dual Eligible (FIDE) Special Needs Plans (SNP) frailty adjustments.

Star Ratings Weights

The most notable provisions of the 2016 Call Letter impacting plans providing care to dual eligible individuals are those related to the Star Ratings program, which we covered in-depth in Monday’s post. As we discussed, this fall CMS released a Request for Information soliciting research showing that plans with a high proportion of dual eligible or LIS enrollees are disadvantaged under the Star Ratings program. CMS released many of the submissions last week, as well as its internal research and analyses. From this research, CMS found that, although there is no evidence to “definitely” identify low-income status as driving the differences in Star Ratings, there may be a correlation between dual/LIS status and the outcomes of a subset of measures. Specifically, after examining 19 of the 46 Parts C and D Star Rating measures, CMS found that LIS/dual status had an impact on the outcome of nine of those measures. For seven of the nine, CMS is proposing to reduce the weight of the measure by half. The measures include: breast cancer screening, colorectal cancer screening, diabetes care – blood sugar controlled, osteoporosis management in women who had a fracture, rheumatoid arthritis management, reducing the risk of falling, and medication adherence for hypertension (for Part D Plans (PDPs) only). This adjustment is proposed for all plans, regardless of a contract’s percentage of dual and/or LIS enrollees.

Please refer to Monday’s post for additional information on these and other proposed changes to the Star Ratings program. Continue Reading CMS Call Letter: Provisions Related to Dual Eligible and Low Income Subsidy Individuals

In its February 20, 2015 Advance Notice of Methodological Changes for Calendar Year (CY) 2016 for Medicare Advantage Capitation Rates, Part C and Part D Payment Policies and 2016 Call Letter, CMS addressed a variety of issues relating to its Star Ratings system. The three most notable being (1) changes and new considerations in the Star Ratings system, (2) an announcement of the quality bonus payment percentage, and (3) the establishment of the timeline under which plans will receive notification that their contracts will be terminated as a result of having three consecutive years of star ratings below three stars. The topics themselves demonstrate that the information in the Call Letter sets the stage for plans to be very big winners or very big losers.

Changes to the System

The most noteworthy announcement related to Star Ratings in the Call Letter is CMS’s discussion of whether plans with a high percentage of dual eligibles and/or low income subsidy (LIS) enrollees are disadvantaged by the current Start Ratings system when compared to plans that do not serve a large duals or LIS population. CMS had previously released a Request for Information that gave interested parties the opportunity to provide analysis and research that demonstrated that dual status negatively impacts Parts C and D quality measures. CMS received multiple comments from a variety of entities relating to this topic and conducted its own extensive research, and while it seems to still be questioning the causal link, has proposed to reduce the weight of six Part C measures and one Part D measure for all plans. The affected Part C measures are: breast cancer screening, colorectal cancer screening, diabetes care – blood sugar controlled, osteoporosis management in women who had a fracture, rheumatoid arthritis management, and reducing the risk of falling. The affected Part D only (not MA-PD) measure is medication adherence for hypertension. CMS recognized that after additional research, it may be appropriate in the long term to adjust Star Ratings where scientific evidence supports that certain measures are impacted by factors including comorbidities, disability, or duals/LIS status. CMS also announced that it is considering developing an integrated Star Ratings system for the Financial Alignment Initiative Medicare-Medicaid Plans (MMPs).

Like last year, CMS included a detailed discussion of changes that will be made to certain measures that comprise the Star Ratings system. Significantly, as proposed in the 2015 Call Letter, CMS has decided to remove pre-determined 4-star measure thresholds for the 2016 Star Ratings. This change impacts 22 Part C and 5 Part D measures. CMS explained that it has seen plans achieve greater improvements in measures without pre-determined 4-star thresholds and believes that the thresholds can sometimes skew ratings when plans are close to the threshold but fall on different sides of the line.

Some of the measures that are being added, returning, or adjusted include the following categories: MTM completion rate for comprehensive medication reviews (Part D), breast cancer screening, beneficiary access and performance problems (Parts C and D), controlling blood pressure (Part C), timely decisions about appeals (Part C), all-cause readmissions (Part C), complaints about plans (Parts C and D), and certain medication adherence measures relating to diabetes medications, hypertension, and cholesterol. The Call Letter also lists measures that are being retired or temporarily removed. Continue Reading CMS Call Letter: Changes to and Implications of Star Ratings

By Tara E. Swenson

Yesterday, CMS released its 2014 Final Call Letter for the Medicare Advantage and Medicare Part D programs. Along with the Final Call Letter, CMS published a brief press release highlighting a handful of changes to the programs. In its press release, CMS focused on changes to the Medicare Advantage Risk Adjustment payment system, its efforts to reduce Part D beneficiary out-of-pocket spending, and limits on Medicare Advantage plans’ ability to increase beneficiary costs.

We will be providing further analysis of the Final Call Letter and changes made as the result of comments to the Draft Call Letter in the upcoming week.