On Jan. 3, the AAMC submitted comments to the Centers for Medicare & Medicaid (CMS) in response to the contract year 2025 Medicare Advantage and Medicare Part D policy and technical changes proposed rule. The proposed rule covered various policy topics related to Medicare Advantage (MA) and Part D plans including policies related to network adequacy, supplemental benefits, dual special needs plans (D-SNPs), formulary substitution of biosimilars, and additional policies.
Of the proposals provided, the AAMC’s letter supported efforts to expand network adequacy standards for mental and behavioral health, reduce misleading marketing and advertising tactics from MA plans, and expand existing utilization management committee requirements to include an annual health equity analysis of the use of prior authorization. The CMS also offered proposals to increase D-SNP enrollment flexibilities and reduce look-alike plans that would limit the number of D-SNP plans offered by MA organizations. The letter urged the agency to mitigate negative impacts this may have on access prior to adopting policies that may limit the number of D-SNPs offered by MA organizations. The CMS also provided updated policy proposals on changes to approved formularies for Part D plans, specifically focusing on biosimilar biological product maintenance changes and the timing of substitutions. In its comments, the AAMC supported the agency’s efforts to advance the use of biosimilar biologic products, but asked the CMS to ensure changes would not affect beneficiary access. Lastly, the AAMC emphasized a need for the agency to consider expanding the utilization data available to relevant invested parties related to MA plans.