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Comments on the health insurance information request


Loren Adler, Matthew Fiedler, Richard G. Frank, and Marta E. Wosinska submitted a letter of comment in response to a recent information request (RFI) relating to the Medicare Advantage (MA) program issued by the Centers for Medicare and Medicaid Services (CMS).

The authors applaud CMS’s interest in improving the MA program, which now serves approximately half of all Medicare beneficiaries. The letter addresses seven specific issues raised by the RFI:

  • Improve the accuracy of risk adjustment to ensure appropriate plan payouts;
  • Using risk adjustment to advance health equity;
  • Advance equity by better coordinating care for seniors in HUD affordable housing;
  • Improve quality by increasing accountability of the MA plan for behavioral health care;
  • Improve transparency and competition by more accurately displaying MA plan premiums;
  • Improve understanding of vertical integration between MA plans and vendors; and
  • Use direct measures of patient access to assess network adequacy.

The letter also stresses that, while improving MAID is more important than ever, it is essential that CMS also continues its efforts to improve traditional Medicare(TM). TM still enrolls about half of Medicare beneficiaries, and TM is likely to attract a significant number of enrollments for the foreseeable future. Additionally, TM’s performance has major implications for the MA program. Payments to MA plans are directly based on TM spending, and competition from TM likely plays a large role in disciplining MA plan offerings and the prices MA plans pay providers. While some of the changes needed for TM (such as adding a reimbursement limit for beneficiaries or modernizing its benefit design in other ways) would likely require legislation, CMS has a variety of tools he could use to encourage more effective care delivery. in TM, including expanding the use of alternative payment models, improving the design of these models, and the targeted use of usage management tools in TM.

Read the full comment letter here.

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[1] J. Michael McWilliams, “Don’t Look Up? The Trajectory of Medicare Advantage and the Future of Medicare,” Forefront of healthcare business (blog), March 24, 2022, https://www.healthaffairs.org/do/10.1377/forefront.20220323.773602/.

[2] Matthew Fiedler, “Price Caps or Creating a Public Option: How Would They Change What We Pay for Health Care?” (Brookings Institution, November 19, 2020), https://www.brookings.edu/research/capping-prices-or-creating-a-public-option-how-would-they-change-what-we-pay-for -health-care/.