AAMC Jan. 16 submitted a comment letter in response to the Centers for Medicare and Medicaid Services’ (CMS’s) proposed rule outlining technical changes to the Medicare Advantage (MA) and Prescription Drug Benefit (Part D) programs. The AAMC urges CMS to ensure that beneficiaries enrolled in MA and Part D plans continue to have access to providers and pharmacies with which they have long-standing relationships. In an effort to decrease burdens associated with reporting requirements, CMS should work to align any new physician reporting requirements with information currently collected.
Flexibility in MA Uniformity Requirements
AAMC agrees that plans must be held accountable for ensuring “compliance with non-discrimination responsibilities and obligations” to guarantee that all beneficiaries enrolled in these plans receive the care they need. Additional supplemental benefits for some beneficiaries should not be at the expense of others. Differential cost-sharing should be implemented only to the extent that it is evidence-based and carefully targeted so as to encourage appropriate utilization to improve outcomes as they relate to specific disease conditions. Furthermore, supplemental benefits and services should be tailored with all beneficiaries in mind. When designing benefits, plans should take into account the needs of beneficiaries who require specialized care and have come to rely on academic medical centers to receive it and should continue to have that care available to them with no additional cost-sharing.
MA and Part D Quality Rating System Updates
In many previous comment letters and meetings, the AAMC has expressed concerns to CMS about the Hospital Star Ratings, including the need for better adjustments for socio-demographic status and other factors, and the worry that in its current form the ratings do not provide consumers with accurate information on which to base important health care decisions. The AAMC notes that CMS has previously finalized policy to adjust the MA Star Ratings metrics for plans that serve a disproportionate number of low-income beneficiaries. The AAMC urges CMS to incorporate similar changes into the Hospital Star Ratings. AAMC member hospitals disproportionately treat disadvantaged and vulnerable patient populations.
Reducing Provider Burden
The AAMC believes better alignment is needed between Star Ratings and Medicare physician quality programs, such as the Quality Payment Program (QPP). Oftentimes, the activities a physician is required to participate in to comply with requirements that earn an incentive for a plan do not align with QPP, meaning that they then need to participate in a separate set of activities in order to meet QPP requirements. This lack of alignment between adherence to plan requirements and quality payment program requirements leads to an increased administrative burden for physicians and forces physicians to address competing priorities between the multiple sets of requirements. While increased quality measures can lead to better quality of care, it also leads to a significant burden shouldered most significantly by physicians, increasing the amount of time they spend on administrative tasks instead of with patients.
Changes to Medical Loss Ratio (MLR) Requirements
The AAMC recognizes the importance of fraud prevention activities. However, quality improvement activities should not include costs that focus on improving the quality of the insurance plan itself or activities related to cost containment that benefit the insurance plan. The AAMC is concerned that the CMS proposal could artificially increase plans’ MLRs, thus providing an inaccurate picture of the amount of premium dollars actually spent on medical costs. The MLR should include only those costs designed to improve health care quality by producing results that can be objectively measured and verified.