CMS Proposes Changes to Risk Adjustment Payment, Supplement Benefits in Draft Call Letter

by Lauren Flynn Kelly

CMS recently proposed several changes for Medicare Advantage and Part D plans in its 2020 Advance Notice and draft Call Letter.

Of note, observes Michael Adelberg, a principal with Faegre Baker Daniels Consulting and a former top CMS MA official, is a discussion around possible changes to the Categorical Adjustment Index. CMS for the 2017 star ratings applied this interim adjustment to address the within-contract disparity in performance associated with a contract’s makeup of low-income subsidy and dual eligible and disabled beneficiaries.

"The work to further risk-adjust medication adherence measures is worth watching," says Adelberg, referring to draft recommendations made by the Pharmacy Quality Alliance. "It could set a precedent for further risk-adjusting other measures based on socioeconomic status."

The Call Letter also contained expected guidance on supplemental benefits targeted to beneficiaries who meet a specified definition of chronically ill. CMS proposed establishing a new, even broader category of Special Supplemental Benefits for the Chronically Ill.

"That's an area where I think we might see some plans show interest in that additional flexibility and try to take advantage of that to create benefit offerings that are more attractive to those chronically ill members and keep them as healthy and happy as possible," observes Brad Piper, a principal and consulting actuary with the Milwaukee office of Milliman.

In outlining new opioid policies, CMS said plans may also use new benefit flexibility to offer targeted benefits or lower cost sharing to patients with chronic pain or undergoing addiction treatment, and encouraged Part D sponsors to provide lower cost sharing for opioid-reversal agents.

From RADAR on Medicare Advantage