Better Medicare Alliance (BMA), the leading advocacy coalition supporting Medicare Advantage, submitted a comment letter today signed by 49 ally organizations responding to the CY2017 preliminary Medicare Advantage (MA) Advance Notice and Call Letter released by the Centers for Medicare and Medicaid Services (CMS) on Feb. 1
FOR IMMEDIATE RELEASE
Contact: Adjoa Adofo, 202-735-0037
Washington, D.C. (March 4, 2016) – Better Medicare Alliance (BMA), the leading advocacy coalition supporting Medicare Advantage, submitted a comment letter today signed by 49 ally organizations responding to the CY2017 preliminary Medicare Advantage (MA) Advance Notice and Call Letter released by the Centers for Medicare and Medicaid Services (CMS) on Feb. 19.
The letter outlines key concerns and requests made by BMA on behalf of the coalition of nurses, doctors, plans, employers, retiree organizations, and beneficiaries. These include asking CMS to:
• Not change MA retiree coverage that would result in an estimated 2.5-2.8% payment reduction to employer, government, and union retiree MA plans, officially known as Employer Group Waiver Plans (EGWPs)
• Ensure a stable risk adjustment system, more transparency in payment calculations, and smooth transition to using encounter data as a diagnosis source
• Ensure that future changes to the Star Rating program successfully incentivize high-quality care for all beneficiaries in all plans
• Limit significant administrative and payment changes
• Provide more robust impact analysis on proposed policies to encourage and enable stakeholders and the public to best assess the consequences of the policies
“The most important goal for BMA is to ensure that all Medicare beneficiaries, including retirees, have access to the high-quality care offered in MA,” said Allyson Y. Schwartz, BMA CEO and President. “We believe that CMS believes in the value of Medicare Advantage and the shared goal of integrated health care that enables access to affordable, quality care. BMA looks forward to continuing to work together towards our shared goals for the Medicare Advantage program and Medicare beneficiaries.”
CMS requested public feedback on the proposed changes by Mar. 4. In addition to a letter signed by allies, BMA submitted letters from beneficiaries enrolled in MA retiree group plans.
BMA Calls on CMS to Protect Medicare Advantage Retiree Plans
In the 2017 Advance Notice, CMS stated it believes that terminating the MA retiree coverage bid process will avoid cost and administrative burden. In the letter, BMA argues that the change will have the opposite effect resulting in a significant 2.5-2.8% payment reduction of payment, operational difficulties, and ultimately discourage employers from continuing to provide these offerings. BMA continues to state that key differences between MA retiree group plans and individual MA plans are dismissed in the proposed changes.
The following are comments from BMA allies in response to CMS’ proposed changes to EGWPs:
Mary R. Grealy, President of the Healthcare Leadership Council said, “There are approximately three million retirees who receive health coverage through Medicare Advantage Employer Group Waiver Plans (EGWP). These older Americans are staying healthier through, among other features, care coordination, disease management programs and prescription drug coverage. Proposed changes to EGWP payment methodologies could result in these plans being costlier and less accessible to seniors. CMS should not implement changes like these, with such far-reaching ramifications, until we can be certain that they won’t adversely affect retirees’ health and well-being.”
Katie Mahoney, Executive Director, Health Policy with the U.S. Chamber of Commerce said, “With the release of the draft call letter, we are reviewing and analyzing the possible impacts of the proposed policy and reimbursement changes on Medicare Advantage plans and Part D generally and Employer Group Waiver Plans (EGWPs) more specifically. EGWPs are a highly valued form of coverage for more than 3 million retirees, approximately 19% of all Medicare Advantage members in 2015, and as an organization representing employers, many of whom offer EGWPs to their retirees, we remain concerned about any negative effects that the proposed policy changes may have on beneficiaries. At a time when the Administration is rewarding providers that move towards alternative payment models and away from fee for service, we urge continued support for these employer based MA offerings which similarly are providing beneficiaries with access to coordinated and comprehensive coverage and services that are not available in traditional fee for services Medicare.”
Neil Trautwein, Vice President of Health Care Policy, National Retail Federation, said “As the world’s largest retail trade association we are concerned about the CMS proposal to make it harder for employers to provide Medicare Advantage benefits to retirees. A growing number of employers are turning to Medicare Advantage because it is an effective way to provide quality and affordable benefits for retirees across the country. We are concerned that proposed policy changes could disrupt employers’ ability to provide retirees with comprehensive health benefits.”
Christine Scullion, Director, Human Resources Policy, National Association of Manufacturers, said: “The National Association of Manufacturers is concerned about unsustainable healthcare costs for manufacturers, which is why we are opposed to the CMS proposal to change the Medicare Advantage coverage available to employers and retirees. The proposal threatens manufacturers ability to provide quality healthcare coverage. A reduction in benefits for retirees will make it harder for manufacturers to provide Medicare Advantage benefits, which have been shown to lower healthcare costs, provide care coordination and increase flexible coverage options.”
Ray Quintero, Senior Vice President of Public Policy, American Osteopathic Association, said “The osteopathic medical profession supports the need to incentivize access to high-quality, patient-centered care for the millions of seniors who depend on Medicare Advantage. We urge CMS to ensure the significant changes proposed to retiree benefits do not negatively impact beneficiary access to adequate networks and innovative delivery models.”
Jane Cheshire Gilbert, CPA, Director of Retiree Health Care, Kentucky Teachers’ Retirement System, said “Medicare Advantage provides critical care coordination and cost-savings for the Kentucky Teachers’ Retirement System. Proposed changes to the Medicare Advantage Employer Group Waiver Plans have the potential to increase future costs for our retired educators. I hope these valuable health benefits provided by Medicare Advantage for retired teachers in Kentucky will be preserved and protected for future retirees.”
Lev Ginsburg, Director of Gov’t Affairs, The Business Council of New York State, said “New York’s employers are concerned about the care given to their retirees, many of whom are in enrolled in Medicare Advantage plans. Any disruption to these plans would be detrimental to our retirees and others in our communities.”
Bill Hammond, CEO, Texas Association of Business, said “Retirees in Texas and across the country depend on access to high quality and affordable Medicare Advantage options. We are concerned that changes to Medicare Advantage Group Waiver Plans will negatively impact access to health coverage with out-of-pocket cost protections for retirees.”
Allen Gutierrez, National Executive Director, The Latino Coalition, said: “The Latino Coalition supports the additional benefits, value and options provided to beneficiaries by Medicare Advantage. We are concerned the proposed changes to employer-sponsored plans will undermine the ability of Medicare Advantage to provide quality benefits such as vision, dental, hearing and in-home care. We support minimizing disruptions and preserving the option of value-based care for Medicare Advantage given that 44% of Hispanic Medicare beneficiaries have already chosen Medicare Advantage over Traditional fee-for-service Medicare.”
BMA Calls on CMS to Ensure a Smooth Transition to Encounter Data
In the letter, BMA emphasized concerns about the CMS’ proposal to accelerate movement towards encounter data as a diagnosis source. BMA contends that providers and plans are not ready for the proposed aggressive timeline and that the change could result in less accurate risk scores. The following are comments from BMA allies in response to CMS’ proposed use of encounter data:
Chester Speed, Vice President of Public Policy, American Medical Group Association (AMGA), said: “The American Medical Group Association (AMGA) appreciates CMS’ effort to maintain the viability of the MA program, which is vitally important to millions of Medicare beneficiaries and AMGA members…AMGA previously expressed concerns that it will be difficult for healthcare providers to capture the appropriate encounter data if their electronic health records do not have the appropriate fields. AMGA will carefully examine this proposal but is extremely concerned that CMS is proposing to increase its reliance on encounter data.”
Ken Coburn, President, CEO, Medical Director, Health Quality Partners, said “Health Quality Partners is concerned that a sudden increased reliance on encounter data, unless done thoughtfully, could result in under-recognition of patients with chronic conditions who need additional care coordination, disease management, or advanced preventive care services. Ongoing review and analyses to determine how best to use encounter data to reliably identify populations at high risk is needed or the quality of care to our most frail and vulnerable could be compromised.”
BMA Calls for CMS to Ensure Stability in Risk Adjustment and Better Align the Star Ratings Program with Value-Based Payment
In the letter, BMA reiterated its support for an accurate risk adjustment model that enables early intervention, coordinated care, and resources required to meet the needs of beneficiaries especially individuals with complex chronic conditions. BMA indicated support for CMS’s work to ensure adequate resources are available for individuals who are dually eligible for Medicare and Medicaid. However, BMA expressed concerns about the continually changing CMS-HCC Risk Adjustment Model without information assessing impact and consequences. BMA also called for CMS to ensure proposed changes does not result in lower quality standards for low-income beneficiaries.
Robert Blancato, Executive Director, National Association of Nutrition and Aging Services Programs (NANASP), said: “The proposed changes in the risk adjustment model could have a significant impact on some dual eligible beneficiaries. We especially call on CMS to provide more detail on how the proposed changes would impact “partial dual eligibles.” With regard to the star ratings system changes, we feel that plans that serve dual eligible beneficiaries should not be unfairly disadvantaged; however, these plans should be held to the same high standards as other plans. Dual eligible beneficiaries deserve the same quality of care as other Medicare Advantage beneficiaries.”
Additional comments from BMA allies on Medicare Advantage:
Gary Puckrein, President and CEO, National Minority Quality Forum, said: “The National Minority Quality Forum believes Medicare Advantage provides quality and affordable care for even the most vulnerable beneficiaries. Patients with chronic diseases like diabetes benefit from the care coordination, innovation and access to enhanced benefits provided by Medicare Advantage. It’s critical that proposed policy changes do not deny beneficiaries access to the highest quality care.”
Jim Parker, President of IUH Plans, said: “Indiana University Health Plans is transforming the way a health plan works with physicians to improve quality of care for our patients while driving down costs,” said. “CMS should fully support and encourage the growth of Medicare Advantage which delivers enhanced value and care for Hoosier seniors.”
Stephen Ferrara, Executive Director, Nurse Practitioner Association New York State, said “The Nurse Practitioner Association New York State supports the high standards in healthcare delivery provided by Medicare Advantage. We oppose proposed policy changes by CMS that undermine the strength of Medicare Advantage. Please prevent disruptions to Medicare Advantage that would result in reduced benefits, fewer plan choices or higher prices for beneficiaries.”
Jaime Estremera-Fitzgerald, CEO, Palm Beach Area Agency on Aging, said: “We urge CMS to ensure all seniors and adults with disabilities have access to comprehensive, quality and affordable Medicare Advantage plans. Over 37% of Medicare Advantage enrollees have annual incomes of less than $20,000, which is why low-income seniors depend on quality and affordable Medicare Advantage plans that facilitate care coordination, early intervention and value-based care.”
Better Medicare Alliance | The Better Medicare Alliance (BMA) is the leading coalition of nurses, doctors, employers, aging service agencies, advocates, retiree organizations, and beneficiaries who support Medicare Advantage as an option under Medicare. Medicare Advantage offers quality, affordability and simplicity, with enhanced benefits to more than 17 million Medicare beneficiaries across the United States of America. BMA works to ensure the sustainability and stability of Medicare Advantage through information, research, education, and united support among stakeholders to strengthen this important coverage for seniors and people with disabilities. For more information, please visit www.bettermedicarealliance.org.