As It Sorts RFI Responses, CMS Considers MA Plan Flexibilities

By Lauren Flynn Kelly - May 25, 2017

In the 2018 final payment notice and Call Letter issued last month, CMS threw in an unusual request for information (RFI) soliciting ideas on ways it can bring more transparency, flexibility, program simplification and innovation to the Medicare Advantage and Part D programs. The agency has received more than 130 responses from a variety of stakeholders and is beginning the process of analyzing the pros and cons of the many suggestions and what they require in terms of subregulatory/regulatory guidance and statutory changes, according to Demetrios Kouzoukas, who was recently appointed principal deputy administrator and director with the Center for Medicare.

During a keynote address given at the Medicare Advantage and Prescription Drug Plan Spring Conference, held May 10 in Baltimore, Kouzoukas emphasized CMS’s interest in collaborating with plans to bring more innovation and flexibility to the MA program and encouraged plans to take advantage of the flexibilities that currently exist in tailoring their services for beneficiaries.

He said the comments received by CMS can be broken into three general categories and offered several examples for each:

1.     Streamlining and improving CMS’s oversight and management of plans. For example, commenters urged CMS to reconsider the way it provides subregulatory guidance and adopt a “more coordinated process” to communicating guidance that could involve frequent updates to the manuals and fewer notices sent via the Health Plan Management System.

2.     Enhancing the beneficiary plan selection process. “Our focus is to improve the visibility of the beneficiaries in the Medicare program to identify the best options for them,” stated Kouzoukas. He said CMS received suggestions on streamlining the marketing materials process and developing more beneficiary-friendly materials, implementing paperless marketing and comparing MA options with fee for service. “These are all really fascinating ideas,” he remarked. “I assure you we’re working diligently on a lot of these proposals.”

3.     Innovating program design to provide options in improving care. Suggestions were provided around “modernizing” the risk adjustment model, payment methodologies and coding guidelines — “Obviously an important area,” he said, although revisions may require statutory change — and expanding benefit flexibilities in MA around uniform benefits, telehealth and network adequacy. CMS also received recommendations around providing greater flexibility in Part D to manage costs, including the expansion of Part D network flexibilities and changes to any willing pharmacy rules.

In addition to considering these and other potential enhancements to the program, Kouzoukas said CMS is establishing a working group “to identify critical issues in processing encounter data.” After receiving extensive comments from plans and other stakeholders on its proposal to keep the same blend of encounter data system and risk adjustment payment system scores in determining risk-adjusted reimbursement, CMS in the final rate notice scaled back the use of 25% EDS to just 15% for 2018. The agency is working to ensure that its internal operations are functioning effectively so that it can process plan submissions accordingly, asserted Kouzoukas. “We do intend to ensure that encounter data is a fully robust system and that we have the ability to collect complete and accurate data,” he stated.

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