Better Medicare Alliance Blasts “Incomplete Data” in Misleading OIG Report Attacking Health Risk Assessments

Washington, D.C. – Better Medicare Alliance (BMA), the leading research and advocacy organization supporting Medicare Advantage, responded to an Office of Inspector General (OIG) report related to Health Risk Assessments (HRAs) in Medicare Advantage.

“Medicare Advantage is built on a value-based framework in which health plans are paid prospectively based on the health risk assessed for beneficiaries in the prior year, rather than being paid for services rendered. Accurate risk assessments for each beneficiary is both a requirement and essential to Medicare Advantage plans, providers, and beneficiaries” said Allyson Y. Schwartz, President and CEO of the Better Medicare Alliance. “HRAs provide important clinical benefits to Medicare Advantage members by identifying health care needs and enabling beneficiaries’ care teams to effectively coordinate their care and combat known illnesses. Such critical management tools should not be attacked with incomplete findings and misleading reporting.”

Schwartz added, “Our reading of the report indicates serious limitations in the data used and assumptions made in the analysis, with findings made on roughly 1% of payments in Medicare Advantage in 2017. OIG itself acknowledges that the report ‘did not determine whether diagnoses reported only on HRAs were supported by documentation in beneficiaries’ medical records’ nor did it determine ‘whether each MAO had submitted all required encounter records.’ The data used was limited to encounter data which was still newly in use and considered incomplete. The fact that the analysis did not include the vast majority of claims makes the data itself insufficient and risks distorting the true utilization of HRAs, which are essential to managed care. Such glaring omissions in the OIG’s report render the findings and subsequent recommendations questionable at best.” 

Schwartz concluded, “Even OIG’s own reporting acknowledges the important role played by HRAs. We agree. HRAs offer the opportunity – particularly in the initial year of enrollment – to meet the beneficiary in their home, provide an assessment of risk, and encourage the new enrollee to schedule a visit with their Medicare Advantage provider. The risk scores also serve the function of assessing the person’s risk for the next year as required in Medicare Advantage and, importantly, it allows for further outreach to the beneficiary based on their health status. Better Medicare Alliance looks to constructive analyses that can improve the care and coverage for beneficiaries. Without more complete data, including what services may or may not have been provided in the following year, this report fails to offer useful recommendations.”

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