Over 28 million seniors and people with disabilities depend on Medicare Advantage (MA) because it provides better services, better access to care, and better value when compared to Original Medicare. And while prescription drug prices continue to spiral out of control, Medicare Part D premiums have remained steady due to plans using tested and effective cost management and other tools to help negotiate lower costs.
To support regulatory recommendations to keep both programs strong, AHIP submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) on its proposed rule for 2023 policy and technical changes to the MA and Medicare Prescription Drug Benefit Program.
Health insurance providers are committed to helping the millions of Americans who depend on MA and Medicare Part D live healthier lives:
“Our recommended changes are designed to maintain and grow strong and stable MA and Part D programs so millions of seniors and people with disabilities continue to receive the high-quality, coordinated care they deserve and rely on. We look forward to continuing to work together on policies that ensure affordable and innovative choices in MA and Part D to improve the health and well-being of Americans.”
AHIP supports regulatory recommendations to strengthen and improve the MA and Part D programs, including:
- Enhancing Integration of D-SNPs: CMS’ leadership on enhanced integration of Medicare and Medicaid through dual eligible special needs plans (D-SNPs) and its future plans to transition away from Financial Alignment Demonstrations and into a more far-reaching and permanent D-SNP program.
- Improving Consumer Experience: Certain proposals to clarify and improve the health care experience for consumers, such as CMS’ clarifications regarding special requirements that apply to out-of-network services during disasters and emergencies.
AHIP also reaffirms its support for CMS’ interest in exploring ways that MA plans can help further improve health equity and provided feedback to the agency on future health equity measures and concepts for the Star Ratings program in recently submitted CY 2023 Advance Rate Notice comments.
However, several key changes in the proposed rule would limit flexibility, choice, competition, and value for consumers, and AHIP recommends:
- Withdrawing Point-of-Sale Pharmacy Price Concessions Proposal: AHIP urges CMS to withdraw the proposal to require all possible pharmacy price concessions be included in a Part D plan’s point-of-sale “negotiated price,” which would not address the cause of out-of-control drug prices and result in higher Part D premiums for seniors and fewer $0 premium MA-PD plans for enrollees in Medicare Advantage. If CMS moves forward, the effective date must be delayed until at least 2024 so that the changes can be operationalized while minimizing disruption for enrollees as much as possible.
- Revising Certain Star Ratings Proposals due to COVID-19 Effects: AHIP recommends that CMS make several changes to MA Star Ratings including extending its COVID-19 disaster relief policy and special rules to all applicable measures and maintaining the relative weighting of patient experience measures for 2023 Star Ratings, due to the impact of COVID-19 on the health care delivery system and performance period.
- Considering Alternatives on MOOP Limit Calculations to Better Protect Beneficiaries: AHIP is concerned that certain D-SNP proposals including the provisions relating to calculating the maximum out of pocket (MOOP) limits and D-SNP only contracts could significantly increase premium costs and/or limit available supplemental benefits.