{"id":21803,"date":"2022-08-22T17:07:20","date_gmt":"2022-08-22T21:07:20","guid":{"rendered":"https:\/\/medicareadvocacy.org\/?p=21803"},"modified":"2022-08-22T17:10:11","modified_gmt":"2022-08-22T21:10:11","slug":"medicare-agency-is-seeking-comments-on-medicare-advantage","status":"publish","type":"post","link":"https:\/\/medicareadvocacy.org\/medicare-agency-is-seeking-comments-on-medicare-advantage\/","title":{"rendered":"Medicare Agency is Seeking Comments on Medicare Advantage"},"content":{"rendered":"\n

On August 1, 2022, the Centers for Medicare & Medicaid Services (CMS) published a Request for Information (RFI) that \u201cseeks input from the public regarding various aspects of the Medicare Advantage program. Responses to this request for information may be used to inform potential future rulemaking or other policy development.\u201d The RFI can be accessed from the Federal Register here<\/a>.  Comments are due August 31, 2022<\/strong> and can be submitted online at https:\/\/www.regulations.gov\/document\/CMS-2022-0123-0001<\/a>. The Center for Medicare Advocacy urges beneficiary advocates to do so.<\/span><\/p>\n\n\n\n

Through the RFI, CMS is \u201cseeking feedback on ways to strengthen Medicare Advantage\u201d with the goal, in part, \u201cto create more opportunities for stakeholders to engage with CMS\u201d. \u00a0CMS solicits comments from \u201ca wide variety of voices on the questions below, including beneficiary advocates, plans, providers, community-based organizations, researchers, employers and unions, and all other stakeholders.\u201d<\/span>\u00a0<\/p>\n\n\n\n

As a beneficiary advocacy organization, the Center for Medicare Advocacy is devoted to identifying and addressing barriers to care for Medicare beneficiaries.\u00a0 There are many such barriers in the traditional Medicare program, but in our experience, these problems are almost always exacerbated for enrollees in MA plans<\/strong> \u2013 particularly for those who tend to be more sick and have greater care needs than most MA enrollees, including those with chronic conditions. \u00a0<\/span><\/p>\n\n\n\n

The Medicare Advantage industry and their champions have tremendous resources to promote their views and visions about how MA works for their enrollees.\u00a0 We urge stakeholders across the board<\/strong> \u2013 MA plan enrollees, providers, counselors and others who might not ordinarily take part in federal agency public notice and comment efforts to weigh in with your experiences with Medicare Advantage<\/strong>.<\/span>\u00a0<\/p>\n\n\n\n

The Center for Medicare Advocacy (CMA) will be submitting separate, extensive comments to this RFI; we offer the following overarching points for commenters to consider.\u00a0 (Note that the comments below are arranged by the categories of comments solicited in the RFI, within which CMS poses more than 45 questions; the responses below address some (but not all) of the questions\/issues most relevant to MA plan enrollees.)\u00a0<\/span>\u00a0<\/p>\n\n\n\n

Overview<\/span><\/strong>\u00a0<\/p>\n\n\n\n

In recent testimony before Congress, the General Accounting Office (GAO) noted<\/a> that \u201c[d]ue to our concerns about the program\u2019s susceptibility to mismanagement and improper payments as well as its size and complexity, we have designated Medicare, including Medicare Advantage, as a high-risk program. We\u2014along with [OIG] and others\u2014have identified significant concerns with CMS\u2019s oversight of the MA program [citations omitted].\u201d<\/span>\u00a0<\/p>\n\n\n\n

Over the last several years, a number of unimplemented recommendations concerning improving and enhancing various aspects of MA oversight have been issued by the Office of Inspector General (see OIG<\/a>, 2022), the General Accounting Office (see GAO<\/a>, 2022) and the Medicare Payment Advisory Commission (see MedPAC<\/a>, 2022) \u2013 as well as consumer advocacy organizations (see, e.g., CMA<\/a>, 2020).<\/span>\u00a0<\/p>\n\n\n\n

As a growing number of Medicare beneficiaries enroll in MA plans, CMS must adjust its resources and staff accordingly, and enhance its oversight and enforcement of MA and MA plan sponsors.<\/span>\u00a0<\/p>\n\n\n\n

Advance Health Equity<\/span><\/strong>\u00a0<\/p>\n\n\n\n

CMS seeks feedback, including how it can enhance health equity for all enrollees through MA, focusing on certain populations. \u00a0<\/em><\/span><\/p>\n\n\n\n

Racial and ethnic disparities persist in Medicare Advantage plans (see, e.g., CMS<\/a>, 2021; Kaiser Family Foundation<\/a>, 2021). Those who are more sick tend to disenroll at a disproportionately higher rate from MA plans (see, e.g., Health Affairs<\/a>, 2021; Health Affairs<\/a>, 2020; JAMA<\/a>, 2019; NEJM<\/a>, 2018). \u00a0Even higher rates of disenrollment occur within the last year of life which \u201cmay indicate potential issues with beneficiary access to care or with the quality of care provided\u201d (GAO<\/a>, 2021).<\/span>\u00a0<\/p>\n\n\n\n

CMS must enhance oversight of MA plans to ensure that they are providing required, medically necessary care, including:<\/span><\/p>\n\n\n\n