Press Releases
March 6, 2023

BMA Urges CMS Not to Move Forward on Proposed Changes to Risk Adjustment Model for 2024

Calls on CMS to work with stakeholders to analyze, understand full impact of changes on seniors, particularly those most vulnerable

WASHINGTON – Expressing concerns about negative impacts on low income and dual eligible beneficiaries and those with chronic conditions, the Better Medicare Alliance (BMA) today called on the Centers for Medicare & Medicaid Services (CMS) to not move forward with proposed changes to the risk adjustment model for 2024. BMA submitted a comment letter in response to CMS’ 2024 Medicare Advantage Advance Notice.

BMA raised issues with the changes negatively impacting health care providers, physician organizations, and health systems that provide comprehensive care to the most vulnerable Medicare beneficiaries. Care innovations for beneficiaries with chronic conditions, including value-based care arrangements, would be at risk. Medicare Advantage seniors and individuals with disabilities would see an increase in out-of-pocket costs and barriers to access to high-quality providers.

In addition to not moving forward on the risk adjustment model changes, BMA requested that the one-time technical changes CMS has incorporated into the calculation of the annual growth rate be phased-in to minimize disruption and maintain stability for Medicare Advantage seniors and individuals with disabilities.

“We are especially concerned about proposed changes to the risk model which could negatively impact Medicare beneficiaries, especially those with chronic conditions, those who are low income, and those who are dually eligible for Medicaid,” BMA’s comment letter to CMS read. “As a result, these changes place at risk the substantial progress made in improving care and outcomes for Medicare beneficiaries. Better Medicare Alliance appreciates CMS’ continued efforts to strengthen the Medicare Advantage program and improve access to coverage and care for the 30 million Medicare beneficiaries it serves.”

Separately, 110 organizations representing providers and people with disabilities, low-income, Black, and Latino Medicare Advantage beneficiaries urged CMS to reconsider risk adjustment changes to Medicare Advantage for the 2024 plan year that could negatively impact them.

“Moving forward with the risk model changes would negatively impact the 30 million seniors and people with disabilities served by Medicare Advantage,” said Mary Beth Donahue, President and CEO, Better Medicare Alliance. “Instead of proceeding with the risk adjustment changes, we respectfully request that CMS delay these changes, allow appropriate time for analysis, and work with stakeholders on clinically based revisions to the model. Medicare Advantage seniors who choose Medicare Advantage need CMS to not move forward with these changes.”

To read Better Medicare Alliance’s full comment letter, click here.


Better Medicare Alliance is working to improve health care through a strong Medicare Advantage on behalf of more than 30 million Medicare Advantage beneficiaries. Learn more at

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