CMS recently released a final rule to implement changes to Medicare Advantage (MA) and Part D for 2021. The final rule does encourage the use of telehealth to meet network adequacy requirements as I previously discussed but notably does not include provisions related to lowering drug costs and pharmacy performance measures. In the press release announcing the new rulemaking, CMS stated “[we are] finalizing a subset of the proposed policies before the MA and Part D plans’ bids are due.” They went on to say they would address the outstanding policies in forthcoming rulemaking but were delaying them for now due to the increased focus on COVID-19.
Here are some of the provisions CMS has finalized thus far as noted in their fact sheet:
- Allowing Medicare-eligible individuals with end-stage renal disease (ESRD) to enroll in MA plans starting January 1, 2021
- Modifying medical loss ratio (MLR) calculations to include amounts paid for all services in the numerator as part of incurred claims for MA organizations
- Reducing the number of beneficiaries in rural areas that must live within maximum time and distance standards from 90 percent to 85 percent
- Providing a 10 percent credit when MA plans contract with certain telehealth providers
In addition to the provisions mentioned above, CMS also finalized changes to the star ratings system for MA and Part D. According to the fact sheet, these ratings are meant to “measure the quality of health and drug services received [and] reflect the experiences of beneficiaries and assist beneficiaries in finding the best plan for them.” Additionally, publishing star ratings helps empower beneficiaries and their families to make more informed decisions about their care.
So, what changes did CMS finalize?
Well, they have opted to place greater emphasis on patient experience/complaints and access measures by increasing the weighting from two to four. This change will go into effect for the 2021 measurement period but will not be reflected until the 2023 Star Ratings. Despite this delay, a number of commenters expressed concern about CMS making any changes due to COVID-19. One commenter noted that “data collection challenges could impact 2021, 2022, 2023, and 2024 Star Ratings for some measures” due to the overwhelming focus of our health care system on the ongoing pandemic. In response, CMS stated they were continuing to monitor the situation and would make additional changes if deemed appropriate.
And, in my personal opinion, CMS is making the right move here. While it’s understandable for people to be concerned about the long-lasting impact COVID-19 will have on future years’ data, it shouldn’t be an excuse to just put a pause on making changes altogether. It’ll be interesting to see what changes, if any, are made to the quality rating system and other policies going forward as the pandemic continues to shift everyone’s priorities.