Healthcare industry groups that responded to CMS' 2019 advance notice are optimistic about some of the proposed changes but have reservations about others.
The comment window closed on Monday.
In its notice letter, the Centers for Medicare & Medicaid Services proposed a 1.84% Medicare Advantage rate increase—significantly higher than the 0.45% increase approved for 2018—and other policies that would take aim at the opioid epidemic and redefine home health supplemental benefits.
The agency also proposed payment adjustments that could boost insurers' risk scores and would slow down the expansion of how much encounter data factors into those scores.
Offering a broader definition of supplemental benefits in MA plans would increase patient access to services outside of traditional sites of care and allows insurers greater flexibility to tailor benefits to meet members' individual needs, the Alliance of Community Health Plans said in a letter (PDF) to CMS.
ACHP also said it was pleased to see that CMS was taking steps in Medicare Part D to address the opioid crisis. CMS wants to cap initial opioid prescriptions at seven days and flag beneficiaries who may be at risk for abuse—steps ACHP said many of its member plans already take.
"We appreciate CMS' commitment to providing helpful flexibility for patients and health plans," ACHP President Ceci Connolly said in a statement. "Highly coordinated, patient-centered care is what seniors deserve and what our provider-aligned plans do best."
ACHP recommends that CMS further modify its MA star ratings to focus on sustained performance rather than year-over-year improvement and is urging the agency to make full incentive payments to high quality plans. The group also said that it would like to work with CMS to better integrate telehealth into MA benefits.
The American Hospital Association also praised CMS for addressing the opioid epidemic in its letter (PDF) to the agency. But the AHA suggested that CMS extend MA coverage to outpatient medication-assisted drug treatment.
The group also said it backs CMS' plan to expand supplemental MA benefits, as it could prevent unneeded healthcare use and allows patients to access a "more comprehensive complement of services."
However, the AHA said it is concerned about the use of encounter data in determining risk scores, as that data is "not designed to support MA risk adjustment calculations." Relying on encounter data in these calculations could lead to inaccurate scores, the group said.
Insurance industry groups, including America's Health Insurance Plans, have been critical of that change as well. AHIP said using encounter data for risk adjustment is likely to lead to an effective rate cut.