In the recent 2018 Final Rate Notice and Call Letter, the new Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma made a bold request to the community of Medicare Advantage stakeholders: send ideas for ways to strengthen Medicare Advantage by lifting regulatory obstacles and transforming the Medicare Advantage program to best meet beneficiaries individual needs.
We jumped at the opportunity. We started our process by reaching out to our 84 ally organizations, thought leaders, and policy experts on Medicare Advantage for their perspectives and ideas. This exercise underscored the commitment amongst Medicare Advantage stakeholders to find ways to increase access, expand service delivery innovations, and promote quality in Medicare Advantage. These principles and our alliance’s varied and insightful inputs formed the basis of our response to CMS.
We sought to be bold as we described solutions to barriers and to offer new, actionable ideas for the implementation of policy changes. We hope this submission is the first step to working with CMS to strengthen one of the most important and successful parts of health care today: Medicare Advantage. We encourage the Trump Administration to embrace these ideas to expand Medicare Advantage and use the lessons learned to achieve even greater successes moving forward.
Our recommendations in summary:
- Tools that Enable Beneficiaries to Make Informed Choices: Beneficiaries need consumer friendly tools to make informed decisions. This includes: improving the Medicare.gov Plan Finder to make comparisons easier and search functions more consumer friendly, improving welcome materials for new enrollees, and expanding outreach efforts by CMS to effectively educate and inform beneficiaries on the difference between Traditional Fee-For-Service (FFS) Medicare and Medicare Advantage.
- Quality Systems that are Effective and Aligned: The Star Rating System is an effective incentive, and it should continue to be improved in order to effectively measure clinical outcomes and encourage care management. The system should also be aligned with other quality systems across Medicare. The types of improvements we support include: refining measures, improving measurement of mental illness and behavioral health, and aligning Medicare Advantage with other programs.
- Tailored Benefits that Meet Patients’ Individual Needs: With greater flexibility, Medicare Advantage plans and providers could implement benefit designs to effectively customize care to improve outcomes and deploy new, innovative interventions. These include: increasing flexibility to test and incorporate interventions and best practices into benefits, expanding the testing of Value-Based Insurance Design (VBID) nationwide, improving current care management Star measures, and widening the definition of allowable supplemental benefits to encourage the addition of services that support care such as nutrition services and transportation.
- Care Delivery that is Innovative and Improves Outcomes: Removing barriers to alternative payment arrangements would encourage the move to value in Medicare. These include: creating regulatory parity between Traditional FFS Medicare and Medicare Advantage entities engaged in alternative payment models, releasing Stars Rating System measurements prospectively, removing data sharing obstacles that impede the integration of actionable data, and exploring quality incentives that support value-based arrangements and effective care coordination.
- Stable Payment that Supports Growth and Enables Management of Complex Enrollees: Medicare Advantage requires stable, adequate, and accurate payment to support growth. CMS should remove regulatory barriers and support enrollment opportunities. These include: ensuring adequate payment for complex patients with multiple chronic conditions, supporting Special Needs Plans (SNPs), and providing accurate payments for employer-sponsored Medicare Advantage plans (EGWPs).
We look forward to the opportunity to work with the Administration to ensure that Medicare Advantage has the flexibility and accountability to lead the way in innovative, effective, high value care for millions of Medicare beneficiaries.