This week, the Medicare Rights Center submitted comments in response to the Advance Notice of Methodological Changes for Calendar Year 2019 for the Medicare Advantage CMS-HCC Risk Adjustment Model and Call Letter (Call Letter). The Call Letter outlines CMS’s payment and policy strategies for upcoming plan years. As in years past, Medicare Rights provided comprehensive comments and feedback, highlighting the concerns and issues beneficiaries tell us about on the helpline every day.
This year, many of the proposed changes involved allowing Medicare Advantage Plans more flexibility – in the ways they communicate with beneficiaries, in setting up cost sharing structures to incentivize certain behaviors, and in offering additional benefits. While many of these flexibilities could be used to benefit enrollees, we are concerned that these changes would be more likely to cause confusion; increase risks associated with mistakes; and potentially make it more difficult for CMS and others to evaluate differences between plans.
Already, people with Medicare Advantage can find it difficult to understand what plan is the right choice for their circumstances. Piling on additional options does not lead to more informed choice without some very specific informational resources. We encourage to CMS to move forward in a way that ensures people with Medicare have the resources and tools they need to make informed, timely choices.
CMS also proposed some changes that Medicare Rights urges them to abandon. For example, CMS proposes to remove one component of the Star Rating score on how well a plan handles appeals and how frequently it issues improper denials. That component reflects beneficiary experiences with the plan.
While plans suffer other negative consequences, like financial penalties, for poor beneficiary experiences, Medicare Rights believes eliminating such experiences from the Star Rating, which beneficiaries are much more likely to interact with and rely upon when choosing a plan, might mislead beneficiaries into thinking a poorly performing plan is the best choice for them.
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