The newly released 2019 Advance Notice and draft Call
Letter proposes easing several restrictions around Medicare Advantage benefit
design, which reflects the administration's theme of "empowering" MA
plans.
"The many flexibilities — a new broad definition of
supplemental benefits, health condition specific benefits, geography specific
benefits — have the potential to significantly change Medicare Advantage, by
letting MAOs embrace leading practices from the employer and Medicaid
markets," says Michael Adelberg, a principal with FaegreBD Consulting and
a former top CMS MA official.
CMS would redefine health-related supplemental benefits to
include those that "compensate for physical impairments, diminish the
impact of injuries or health conditions, and/or reduce avoidable emergency room
utilization."
John Gorman of Gorman Health Group describes the expansion
of supplemental benefits as the best news the industry has gotten in years. He
says, "It's going to become the primary weapon plans use to address social
determinants of health."
The Call Letter also calls for uniformity flexibility,
which would allow MA plans to reduce cost sharing, offer specific supplemental
benefits, and lower deductibles for enrollees under certain medical situation.
It permits Special Needs Plans (SNPs) for dual eligible and institutionalized
patients to offer specialized, targeted care through enhanced disease
management programs. The letter adds provisions on ensuring quality and
transparency as well.
However, there were few meaningful changes to the star
ratings in the Call Letter. The most notable was CMS's confirmation that it
will use an enrollment-weighted average to determine the quality rating of
consolidated contracts.
CMS says it will continue to evaluate SNP-specific network
adequacy evaluations and expects to provide further instructions in a future
memo or the final rule.
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