Following up on its promise to advance the timeline for
releasing rates and other information relevant to the 2022 bid cycle, CMS on
Oct. 30 posted Part 2 of the 2022 Advance Notice. Combined with other factors
such as an effective growth rate of 4.55% for fee-for-service Medicare and a
negative FFS normalization factor of 1.64%, the expected average change in
revenue for plans in 2022 is 2.82%.
To Brad Piper, a principal and consulting actuary at Milliman,
the only thing surprising about the document was its early release, which
usually posts in early February. "It either maintained prior provisions or
reinforced changes that CMS had already mentioned were in the pipeline, so
there were no real changes there," he says. Piper adds that the 2.82% increase
is "relatively average."
Pointing out that the preliminary rates are usually subject to
change, Citi analyst Ralph Giacobbe on Nov. 2 observed that the 2.82% change
represents the biggest increase since 2019’s final rate boost of 3.4%. It is
worth considering, however, "that the relatively higher rate backdrop
comes amid COVID-19, when the impact of shelter-in-place orders, bans on
elective procedures, and the behavioral consequences of healthcare utilization
amid a pandemic could result in greater higher acuity and subsequently higher
healthcare spending for the elderly population," he wrote.
"Nevertheless, we see the healthy rate backdrop as favorable for the
MCOs."
In addition, CMS in Part 2 of the Advance Notice sought feedback
on several potential modifications to the Parts C and D star ratings, including
two new Part C measures: (1) Provider Directory Accuracy, which could consider
what percent of plan information is inaccurate, and (2) COVID-19 Vaccination,
which would be added to the Consumer Assessment of Healthcare Providers &
Systems survey.
The addition of the latter was a "little bit
interesting," says Piper. "It's very timely and I think CMS's
approach here is, 'Look, we want to make sure that the COVID vaccine is
provided to seniors as soon as possible,' and so one of the ways that CMS can
put some incentive around that is to create a star measure that would reward or
penalize plans for either being prompt or late with that vaccine
administration."
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