As you may recall, in December 2015, the Securing Fairness in Regulatory Timing Act extended the 45-day notice period for the Medicare Advantage Advance Notice & Draft Call Letter (draft call letter). This means the industry now has 60 days to review the proposed payment and benefit changes, getting a few more weeks to digest the minutiae of the draft call letter. It also means we are now expecting the draft call letter to come out on February 1, earlier than the typical mid-February release.
A few months ago, one could have predicted some fairly standard updates from the Centers for Medicare & Medicaid Services (CMS). As our Stars team pointed out, the annual Request for Comments on Proposed Enhancements to the 2018 Star Ratings program, which are usually incorporated into the draft call letter, will “be remembered not for noteworthy new Star Ratings program information but rather for the absence of significant new insights or new measures.” Similarly, the early rate preview, released December 1, showed a baseline increase of 2.31%. While this number will still be adjusted, it is fairly consistent with recent trends and expectations.
The question now is whether the new administration will have an effect on the draft call letter. We can be sure to see some reference to amendments made through the 21st Century Cures Act, passed late last year. Remember, Cures slipped in some changes to Medicare Advantage regulations as well.
The Medicare Payment Advisory Commission (MedPAC) also just recommended changes to the Medicare Advantage benchmark calculations, however, given the timing and that these recommendations will be submitted to Congress in March, we may not see commentary on this proposal until next year. Specifically, MedPAC recommended the benchmark formula be recalculated and based on only fee-for-service spending data for beneficiaries enrolled in both Part A and Part B, which would likely lead to higher, more accurate payments to plans.
Contact us with any questions about the anticipated draft call letter and for assistance in reviewing its change and impact to your organization.
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