Experts Weigh In on 2027 Medicare Advantage and Part D Proposed Rule

Experts Weigh In on 2027 Medicare Advantage and Part D Proposed Rule

The Centers for Medicare and Medicaid Services (CMS) have proposed a significant rule affecting Medicare Advantage (MA) and Medicare Part D for the 2027 contract year. This proposal aims to enhance the oversight and transparency of these programs.

Key Changes in the Proposed Rule

Among the main aspects of the proposed changes is the expansion of CMS’s authority to release MA encounter data. Matthew Fiedler provided commentary on this proposal, highlighting several important points.

Impact of Broader Data Release

  • The proposal could lead to improved research opportunities concerning MA programs.
  • Release of encounter data may help clarify how MA plans manage finances and care delivery.
  • However, the lack of dollar amounts in the released data poses challenges for comprehensive analysis.

Fiedler suggests that while the CMS aims to keep negotiated prices confidential, such a stance could contradict the broader push for price transparency initiated during the Trump administration.

Considerations on Risk Adjustment Policy

Fiedler also critiqued various potential changes to the MA risk adjustment policy proposed by CMS. He addresses the following key points:

  • Adopting an “inferred risk” model based solely on healthcare utilization may distort care delivery.
  • Integrating specific utilization data with existing diagnosis data could enhance the accuracy of the risk adjustment system.
  • Excluding certain diagnoses from risk adjustments might level competitiveness, yet could lead to inefficiencies in diagnosis capture.

Fiedler argues that simply recalibrating the CMS-HCC model with encounter data might not adequately resolve coding intensity issues and could introduce legal challenges. Structural modifications to the risk adjustment model are necessary, but improving CMS’s coding intensity adjustments is equally important.

Conclusion

As CMS moves forward with the proposed changes for the 2027 contract year, these insights will play a crucial role in shaping the future of Medicare Advantage and Part D. Clarity on pricing and improving risk adjustment systems are essential for the effectiveness of these programs.