Memo on CMS Advance Notice and Draft Call Letter for 2013

CMS continues to refine operational policy for Medicare Advantage and Part D plans.  View our summary of the 45-Day Advance Notice and Draft Call Letter for 2013 by clicking here.   I was disappointed CMS did not finalize their proposed regulations prior to issuing this document.  As a result some of the more significant policy changes will be reserved for the final rate announcement and final Call Letter.

I was struck by how complicated the payment formulas have become.  While use of more recent data should make the formulas more accurate, there are so many other factors that can affect the bottom line in different directions that may be hard to predict, including the recalibrated MA and Part D risk adjustment processes.  The new frailty adjustors for Fully Integrated Dual SNPs should provide an incentive for these plans to grow more rapidly, which is exactly the direction that CMS intends.

The number of quality measures continue to grow, with the most intriguing new measure being the net quality improvement at the Part C and Part D contract level.  But I wonder how plans can keep up with all of the new measures and modifications to current measures each year. CMS continues to advance its value based purchasing agenda, including moving down the path of measuring performance of plans with less than 1,000 enrollees. This will pose some methodological challenges but should provide a more level playing field for plan comparisons.