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AHIP Comments to the 2021 Advance Notice for Medicare Advantage Capitation Rates and Part C and Part D Payment Policies

Comment Letter

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Published on Mar 6, 2020

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Medicare Advantage

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AHIP has submitted its comments to the Advance Notice of Methodological changes for 2021 for the Medicare Advantage Capitation Rates and Part C and Part D Payment Policies.

America’s Health Insurance Plans (AHIP) appreciates the opportunity to comment on Parts I and II of the Advance Notice for Calendar Year (CY) 2021 for Medicare Advantage (MA) and Part D. We also include comments on the CY 2021 Part C Benefits Review and Evaluation (Part C bidding instructions).

Approximately 24 million people – 35% of those eligible for Medicare – choose MA because it delivers better services, better access to care, and better value. Similarly, Medicare Part D has been a model of consumer choice and market competition that has improved access to prescription drugs and reduced out-of-pocket costs for tens of millions of seniors. Currently, 47 million Americans are covered under Part D, with more than 21 million receiving their benefits through an MA plan and more than 25 million through a stand-alone Prescription Drug Plan. MA plans lead the way in advancing innovative, patient-centered programs that improve care, reduce consumer costs, and address the needs of seniors and others who qualify for Medicare.

We strongly agree with CMS’ statement in the Advance Notice that these programs have demonstrated the value of private sector innovation and creativity. However, AHIP and our member health insurance providers have significant concerns with certain proposals in the Advance Notice and bidding instructions that could undermine affordability, stability, and choices for consumers.

Our recommended changes are aimed at maintaining a strong and stable MA program that allows health insurance providers to continue working with others to improve American health care. The changes will ensure millions of seniors and people with disabilities continue to receive the high-quality, coordinated care they deserve, and rely on, through MA.

By working together, we can ensure that Medicare Advantage continues to be a leader in delivering affordability, access, choice, and innovation.