Health plan and industry trade groups are calling on the CMS to delay or not move forward entirely with proposed changes to the 2024 Medicare Advantage and Medicare Part D plans.
The calls come as the 30-day window to submit comments for the CMS’ advance notice lapsed Friday.
Points of contention include the proposed change to MA plan rates. The advance notice, released in January, proposed a 1.03% average MA revenue increase, driven by a 2.09% growth rate.
It’s a decrease from the final rule released in April last year, when CMS approved an 8.5% increase in MA rates with a 4.88% growth rate for MA plans.
Insurance lobbyists argued that the 1.03% plan increase is insufficient and, in combination with other changes, would actually result in payment cuts.
The proposed changes come amid increasing government scrutiny of MA plans, which have soared in popularity in recent years and now serve an estimated 30 million Americans.
In late January, the agency announced that it would begin conducting MA plan audits in an attempt to recoup billions of dollars in overpayments to insurers.
National insurance lobby AHIP called the proposed revision to the 2024 risk model “flawed” in its submitted comments, adding that the 30-day comment allotment was too short for the “extremely complex” proposed changes.
“CMS did not provide an extended comment deadline or an opportunity for engagement in the process of developing the proposed risk model changes, such as through technical papers or other means,” the lobby said in its submitted comment. “This has severely limited the opportunity for meaningful analysis and comment on major changes affecting more than 30 million Americans.”
In AHIP’s comment, the lobby included findings from a study, commissioned by AHIP, that found that proposed changed would result in an average payment cut of 3.7% to MA plans.
The American Group Medical Association, or AMGA, said that the comment period offered little time to analyze or model the risk adjustment changes.
“CMS should not move forward with its proposed change until stakeholders understand what the impacts of these changes will mean to MA plan design and care delivery,” the group said in a statement.
In addition, the AMGA said that it disagreed with removing certain codes from the risk adjustment model.
As part of the advance notice, the CMS proposed changes to the hierarchical condition categories, or HCCs, which assist in calculating risk scores. In 2024, the CMS proposed using ICD-10 codes to create HCCs instead of using ICD-9 codes.
Trade groups like Medical Group Management Association, or MGMA, said that in comments that the CMS provided inadequate transparency for the HCC model changes and did not analyze the estimated effects of the revisions enough.
Regarding the decision to remove over 2,000 ICD-10 codes, “We believe any overhaul to the current CMS-HCC model should be accompanied by detailed information and data on how CMS arrived at these proposals,” MGMA said.
“CMS has provided 30 days for stakeholders to comment on these proposals that could potentially have a significant impact,” the group said. “Group practices need time to understand the full impact these changes could have on delivering care.”
The Alliance of Community Health Plans, or ACHP, said in comments that its plans were requesting a one-year delay of the reclassification portion of the risk-model update, or HCCs.
“While ACHP supports clinical reclassification that maps to ICD-10 codes, CMS has not provided sufficient time to analyze and understand the proposed approach,” the non-profit health plan group said.
The CMS plans to announce its final MA capitation rates and payment policies for 2024 no later than April 3.