Centene Issues Public Comment on Centers for Medicare & Medicaid Services Proposed Rule

Targeted News Service

WASHINGTON, April 13 -- Jonathan Dinesman, senior vice president for government relations at Centene Corp., St. Louis, Missouri, has issued a public comment on the Centers for Medicare and Medicaid Services' proposed rule entitled "Medicare and Medicaid Programs: Contract Year 2021 and 2022 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicaid Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly". The comment was written on April 6, 2020, and posted on April 10, 2020:

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Centene Corporation (hereafter "Centene") appreciates the opportunity to provide feedback on CMS' Proposed Rule: Medicare and Medicaid Programs; Contract Year 2021 and 2022 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicaid Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly, published on February 18, 2020. We appreciate CMS' efforts to ensure the delivery of quality services to Medicare beneficiaries enrolled in Medicare Advantage (MA) and Medicare Part D. Centene looks forward to working with CMS to further beneficiaries' access to robust medical and prescription drug coverage in the Medicare program.

Founded in 1984, Centene has established itself as a leading multi-national healthcare enterprise with a commitment to helping people live healthier lives. The company takes a local approach - with local teams and solutions - to provide fully integrated, high-quality, and cost-effective services to government-sponsored and commercial healthcare programs, focusing on underinsured and uninsured individuals. Centene offers affordable and high-quality products to nearly 1 in 15 Americans across all 50 U.S. states, including Medicaid and Medicare members (including close to 1 million Medicare Advantage members and about 4 million members in Medicare Prescription Drug Plans) as well as individuals and families served by the Health Insurance Marketplace, the TRICARE program, and individuals in correctional facilities. The Company also serves several international markets, and contracts with other healthcare and commercial organizations to provide a variety of specialty services focused on treating the whole person. Centene offers a comprehensive portfolio of innovative, flexible solutions that demonstrate our commitment to delivering results to better serve our members, providers, local communities, and government partners. Centene prides itself on providing high-quality and affordable coverage to our aging populations and deploying innovative senior programs to drive improvements in health outcomes. In the wake of Coronavirus Disease 2019 ("COVID-19"/ "the pandemic"), we are especially committed to supporting our members affected by the pandemic and partnering with CMS to maintain the viability of our health and social support systems. Our comments to this proposed rule are based on our experiences in meeting the evolving needs of our members in the Medicare Advantage and Part D marketplace.

INTRODUCTORY COMMENTS

Before including our detailed comments, Centene would like to highlight the following specific priority areas in the Proposed Rule.

* Dual eligible beneficiaries rely on enhanced care management and coordination to foster alignment across Medicare and Medicaid products and programs. Centene remains aligned with CMS' efforts to improve coordination by transitioning fully eligible members in D-SNP "look-alikes" into more integrated plans when options are available. As part of these efforts, Centene recommends that CMS work with states to help provide care coordination for dually-eligible enrollees who do not yet have a viable alternative to enroll in integrated plans, such as Medicare-Medicaid plans (MMPs), due to state restrictions.

* While we appreciate CMS' release of the Interim Final Rule (IFC) on Medicare policy and regulatory revisions during COVID-19 to addresses the expected disruption to data collection posed by the pandemic, we encourage CMS to consider impacts of COVID-19 that may extend beyond 2021 and 2022 Star Ratings data collection. As CMS proposes changes to 2023 Star Ratings, we ask that CMS remain cautious on pursuing any changes that could further weaken the ability of plans to make quality improvements in the aftermath of COVID-19. For instance, plans with larger shares of low income subsidy (LIS) beneficiaries tend to be disadvantaged by the current quality bonus program./1

The proposed outlier deletion methodology would make it even more difficult for these plans to improve their rating, which disincentivizes plans from taking on these members, contrary to CMS' goals. In addition, given the subjectivity of CAHPS measures and low response rates, patient experience/complaints and access measures are not an accurate indicator of plan performance. Centene urges CMS to not finalize the proposed weight changes and instead focus on measures that target improvements in clinical outcomes.

* The Part D program has been widely successful at expanding health coverage and lowering drug costs through competition, flexibility, and innovation. Centene appreciates CMS' willingness to create a second specialty tier in Part D, which will increase competition and drive member utilization towards cost-effective alternatives. While CMS continues its efforts to lower Part D drug costs, Centene encourages CMS to increase cost-sharing in the non-preferred tier to further drive manufacturer incentives. In addition, enhanced plans provide additional value on this foundation by reducing deductibles and cost sharing for enrolled beneficiaries. Therefore, Centene also supports the allowance of additional plan types beyond the existing limit of 3 plans per PDP region.

* Centene appreciates CMS' definitional adjustments to the MLR and thanks CMS for the additional supplemental benefit flexibilities allowed by this definition. We look forward to offering new supplemental benefit designs that will let us effectively tailor resources to meet the specific health needs of our members.

* Centene supports CMS' proposal to provide greater flexibilities for network adequacy standards, which will help to drive access and increase coverage in rural areas. We greatly appreciate CMS' efforts to encourage telehealth and virtual care to support care delivery in markets with limited specialty access, particularly in the IFC's response to COVID-19. However, given that the IFC's responses are temporary, we encourage CMS to pursue longer-term changes to promote greater access to telehealth. Enhanced flexibility for network adequacy will allow health plans to continue to expand capacity to deliver care through innovative means to areas with high needs. To further drive improvements in care delivery, we suggest that CMS broaden its focus to include other provider specialty types, such as nephrology for home dialysis.

Thank you for the opportunity to submit comments on the Medicare Advantage and Part D Proposed Rule. We remain a committed partner in working with the Administration, particularly during this challenging time, to pursue meaningful policies to promote greater innovation, transparency, flexibility and program simplification.

If you have questions or need more information, please contact me at JDinesman@centene.com or 314.505.6739 or Patti Barnett at Patti.A.Barnett@centene.com or 314.349.3086.

View full comment at: https://www.regulations.gov/contentStreamer?documentId=CMS-2020-0010-0375&attachmentNumber=1&contentType=pdf

Sincerely,

Jonathan Dinesman

Senior Vice President, Government Relations

Centene Corporation

Footnote:

1/ Medicare Payment Advisory Commission (MedPAC), "Chapter 8: Redesigning the Medicare Advantage Quality Bonus Program," Report to Congress: Medicare and the Health Care Delivery System (June 2019). http://www.medpac.gov/docs/default-source/reports/jun19_medpac_reporttocongress_sec.pdf?sfvrsn=0

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The proposed rule can be viewed at: https://www.regulations.gov/document?D=CMS-2020-0010-0002

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