March 14, 2023 – Providers and payers are united in their frustration with the proposed Medicare Advantage rule that they believe will cut payments and affect their ability to provide quality care to consumers.

The providers and insurers submitted comments to the proposed Medicare Advantage advance notice rule that outlines payment rates and risk adjustment changes for 2024.

The Medical Group Management Association (MGMA) submitted comments that included, “We are concerned with CMS’ lack of transparency regarding the estimated effects of the revisions.”

The American Medical Group Association also joined in. “Historically, CMS has phased in changes to the MA risk adjustment model to allow plans and providers to adjust their systems and anticipate the potential effects of the changes,” the AMGA wrote in comments. “However, if finalized as proposed, CMS would not use this approach.”

Their belief is that the new rule would require an MA plan to submit initial bids by June 5, 2023, and this does not provide enough time to study its impact.  MGMA agrees and requested that CMS pause the implementation of the proposed risk adjustment changes to allow more time to study the impact it will have on value-based care models. 

The comments providers submitted regarding the proposed Medicare Advantage advance notice rule is also in line with what health insurers are arguing. Insurers argue that the proposed payment rate will reduce payments. They say this will detract from providers ability to provide quality services and care. 

Insurers, backed by studies from consulting firms, also challenge CMS’s claim that the proposed rule will result in a 1% pay raise. Insurance group AHIP touts a study showing the proposed Medicare Advantage rule would result in a 3.7% decrease in pay, while another study shows payments will be reduced by 2.27%. 

“We believe the Advance Notice is inconsistent with national and CMS policy goals of advancing health equity, improving the healthcare delivery system, expanding use of quality- and value-based payments and enhancing care coordination and disease management,” AHIP wrote.

While there are providers and payers uniting in their opposition to the proposed rule, a group of over 30 health leaders and experts lauded the proposed changes. They claim CMS is merely removing diagnosis codes that plans have used to gain overpayments. 

Despite the opposition and differing opinions, CMS must finalize the Medicare Advantage advance notice rule by April 3, 2023. 

You can access the 2024 Advance Notice in it’s entirety by clicking here.