Last week, the Centers for Medicare & Medicaid Services (CMS) published the 2017 Medicare Advantage Capitation Rates and Medicare Advantage and Part D Payment Policies and Final Call Letter (2017 Final Notice and Call Letter). In March, Medicare Rights submitted comments on the draft version of the call letter supporting of many of the proposed changes, which seek to improve the accuracy of payment structures and strengthen plan accountability. The 2017 Call Letter finalizes most of the proposals included in the draft letter, with some moderate changes.
The changes included in the final version include adjustments to payment methodologies designed to improve the accuracy of payments to plans serving beneficiaries dually eligible for Medicare and Medicaid as well as policies to improve the accuracy of MA plan provider network directories and Part D plan audits related to auto-forwarded appeals cases. CMS will go forward with some other proposals, but on a different time-frame. For example, changes to the way employer-sponsored MA plans are paid will be phased in over time to avoid dramatic reductions in benefits.
The 2017 Call Letter also reflects upon opportunities to improve beneficiary access to medications. The final version increases the minimum price for medications placed on the specialty tier and promises a series of CMS analyses on use of the specialty tier among Part D plans. CMS will consider whether placement on a specialty tier decreases utilization of particular prescription drugs and will assess the impact of allowing tiering exceptions on the specialty tier; to date, these exceptions are prohibited for specialty medications.
Medicare Rights is pleased to see that CMS carefully considered comments received from a wide range of stakeholders, and continues to support many of the policies advanced in the 2017 Final Notice and Call Letter. We remain concerned, however, about minimal progress made on promised improvements to Part D coverage determination and appeals processes. We regularly hear from people with Medicare who face persistent confusion and challenges when denied access to a medication at the point of sale, and we continue to encourage CMS to strengthen the Part D appeals process.