- CMS should work to align quality and performance standards across all Medicare programs, including Medicare Advantage (MA) and the Medicare accountable care organization (ACO) initiatives, says AMGA.
In a letter issued in response to proposed changes to MA and Medicare Part D, AMGA President and CEO Jerry Penso, MD, MBA, argued that more standardization across multiple programs would help reduce Medicare spending and create improved care quality for all Medicare beneficiaries.
The proposed changes from CMS allow MA plans to provide flexible supplemental benefit offerings, cost sharing, and chronic disease benefits. AMGA supports care models like Medicare Advantage, and believes that the changes should be available for all Medicare providers, not just Medicare Advantage plans, so they can compete and drive innovation.
“Supplemental benefits are particularly important for chronically ill or medically vulnerable patients,” said Penso, in an accompanying press release. “This flexibility in benefit design should be available to all Medicare beneficiaries.”
“This proposal is an opportunity to align the disparate parts of the Medicare program,” Penso added. “Should CMS finalize this proposal, similar changes should be implemented across the entire Medicare program to ensure a level playing field.”
AMGA has concerns that the policy changes exclude potential improvements in care quality within Medicare Part B.
The changes would add more flexibilities to Medicare Part C and MA, but exclude Medicare Part B. AMGA argues this is a problem because the Part B program wouldn’t be able to use these flexibilities to treat high-cost beneficiaries that contribute to large portions of Medicare spending.
AMGA suggested that ensuring the changes are uniform would add improvements in premium spending and consumer pricing.
“Assuming CMS continues to make Medicare benefit design and pricing more transparent, competition between Part C and Part B would mean beneficiaries would have more choice and leverage which would translate to decreased premium costs,” AMGA said. “In sum, Medicare would, finally, become a synergistic, coherent program or one greater than the sum of its parts.”
AMGA expressed additional concerns for a proposed change that would eliminate “meaningful difference” requirements, which are limits on how many different MA plans a payer may provide. CMS proposed the change as a way to add MA competition within counties and allow MA payers to focus on the quality of health plan benefits.
AMGA contended that CMS’s rationale for the decision isn’t valid since enrollees already have an average of 18 MA plans to choose from per county. AMGA added that CMS did not provide evidence that meaningful difference requirements inhibited payers from providing high-quality benefits.
AMGA believes that individuals may have difficulty in choosing a plan if there are too many plan options and that meaningful difference requirements may actually be useful for consumers.
AMGA expressed praise of CMS’s efforts to combat “cross-walking,” or when Medicare Advantage organizations (MAOs) receive quality bonus payments when beneficiaries are consolidated from a lower star MA plan into a plan with more stars.
Cross-walking allows a lower quality plan to receive bonus payments they would otherwise not be eligible to receive, and misleads consumers on the quality of health plans, says AMGA. AMGA and CMS both believe that MAOs game the system in this manner so they can increase revenues.
However, AMGA is concerned that CMS plans to remedy this problem by averaging the Star Ratings of the consolidated plans to determine true plan quality. AMGA argues that averaging Star Ratings would overlap geographic quality data.
“AMGA supports policy reform that would report quality at the local market or at the plan level, not the contract level,” the organization added.
AMGA’s comments suggest that the Medicare program stands to benefit from the collective use and participation of value-based care models and health plan design. If the proposed changes are finalized, then they will take effect in plan year 2019.