Radar on Medicare Advantage

In lieu of a draft Call Letter attached to its annual rate notice for the coming year (see story, above), CMS on Feb. 5 issued a 900-page proposed rule containing a slew of non-rate-related changes to the Medicare Advantage and Part D programs for contract years 2021 and 2022. While that rule (85 Fed. Reg. 9002, Feb. 18, 2020) seeks to codify numerous policy changes that were already made via statute and subregulatory guidance — including CMS’s expanded definition of “primarily health related” supplemental benefits and the entry of patients with end-stage renal disease (ESRD) into the MA program starting on Jan. 1, 2021 — it also features new and noteworthy proposals such as flexibility around network adequacy and medical loss ratio calculations, industry experts tell AIS Health.

“There are not game-changers in this regulation, but there are another series of program tweaks that are, in total, pretty helpful to MAOs,” observes Michael Adelberg, a principal with Faegre Drinker Consulting and a former top CMS MA official.

With an estimated pay boost just under 1% and the continued increase of encounter data used in determining Medicare Advantage plans’ risk scores, MA reimbursement in 2021 isn’t looking as robust as it has in recent years now that both parts of the Advance Notice have come out. Meanwhile, MA plans face new uncertainties as patients diagnosed with end-stage renal disease (ESRD) can begin enrolling in such plans on Jan. 1, 2021. And while some changes in Part II of the Advance Notice stand to lower rates for serving ESRD enrollees, CMS in a separate memo proposed a new methodology for setting maximum out-of-pocket (MOOP) cost limits that will partly account for ESRD costs starting in 2021.

CMS, in its Feb. 5 press release announcing Part II of the Advance Notice, said it would accept comments on all proposals contained in the notice through March 6, before publishing the final rate notice by April 6. But the agency did not include or mention the draft Call Letter, which it releases annually with a comment period and usually contains proposals for MA and Part D plans to consider before they submit bids in June. Instead it released a 900-page proposed rule outlining policy and technical changes for contract years 2021 and 2022, and a separate memo with bid and operational instructions for bids due June 1.

✦ Humana Inc. on Feb. 4 said it partnered with private equity firm Welsh, Carson, Anderson & Stowe (WCAS) to expand access to value-based care for Medicare patients. Through the new joint venture, the partners will develop and operate “senior-focused, payor-agnostic, primary care centers” that will be managed by Humana’s Partners in Primary Care subsidiary and operated under the PIPC brand. WCAS is making an initial commitment of $600 million to the joint venture, in which it will have majority ownership. (The firm owns a majority stake in MMIT, AIS Health’s parent company.) Visit https://huma.na/370wr7Y.

✦ By investing in nine weeks of intensive training for 75 community health workers (CHWs), Inland Empire Health Plan (IEHP) on Jan. 23 said it has launched the biggest community health workforce of its kind in the Inland Empire region of California. The newly trained CHWs will support comprehensive care management for IEHP members who have chronic conditions and are enrolled in the state’s Health Homes Program, which targets the highest risk 3% to 5% of Medi-Cal beneficiaries (RMA 9/20/18, p. 3). Visit www.iehp.org.

With supplemental benefits increasingly playing a role in shopping and switching behavior, Medicare Advantage carriers should be doing everything they can to highlight their supplemental offerings for existing and new customers during enrollment periods. And as product design gets underway for the 2021 plan year, MA organizations that want to stand out in their respective markets should survey members now on what inspired 2020 plan selections and use that data to make localized decisions, experts from Carrot Health and Deft Research advised during a recent webinar.

MA enrollees during the most recent Annual Election Period (AEP) had more plans than ever to choose from, with about 21 available plans for every 100,000 enrollees, compared with 15 plans two years ago, according to Carrot Health, a technology firm that uses predictive analytics to help clients deliver targeted strategies. At the same time, plan benefits are richer than ever, with supplemental benefits being offered by new plans at a higher rate than their competitors, said Spencer Pratt, vice president of product with Carrot, during the Jan. 29 webinar, “AEP Results: What’s Happening in 2020?”

Surveys have shown that cognitive decline is a chief concern among aging adults, yet brain health and “memory fitness” remain largely untapped areas as Medicare Advantage insurers experiment with new benefit design flexibility. But as a growing body of research builds a clinical case for so-called “brain training” programs, Posit Science is eager to get its own BrainHQ exercises in front of MA enrollees and says three insurers have incorporated them into supplemental benefits for 2020.

When advising MA organizations on newly expanded supplemental benefits, CMS in an April 2018 memo highlighted a “standalone memory fitness benefit” as one of nine potential services that could be offered starting in 2019 (RMA 5/17/18, p. 1). But a Milliman, Inc. analysis of the 2019 plan benefit package files did not identify any new standalone memory fitness benefits being offered that year. And in 2020 it continued to receive less attention than buzzworthy benefits such as nutrition or transportation or acupuncture (which was offered by 32 plan IDs in 2020, according to a CMS summary of supplemental benefits highlighted on the Medicare Plan Finder). Nevertheless, “the strong clinical case, plus its low cost, suggests it’s only a matter of time before it becomes a common offering,” predicts Michael Adelberg, principal with FaegreBD Consulting and a former top CMS MA official.