Recently, the Centers for Medicare & Medicaid Services (CMS) issued proposed rules to update the Medicare payment rates and implement other policy changes for three types of Part A providers: hospice, inpatient psychiatric facilities (IPFs), and skilled nursing facilities (SNFs). CMS is publishing these proposed rules in accordance with existing statutory and regulatory requirements to update Medicare payment policies for these providers on an annual basis. This brief summarizes the proposed payment rates and key policy changes for each of these provider types.
Medicare
Medicare and Medicaid Telehealth Coverage in Response to COVID-19
Telehealth service expansions by Medicare and most Medicaid programs aim to rapidly increase access to care and reduce transmission, but also provide a natural experiment for policymakers.
This week, our In Focus section examines the extensive scope of flexibilities Federal and State governments have made to Medicare and Medicaid telehealth coverage in response to the COVID-19 national emergency. In March and April 2020, federal and state policymakers responded to the COVID-19 emergency by temporarily and aggressively expanding the definition of and reimbursement for telehealth services—moves intended to improve access to care and reduce virus transmission. Under the Medicare and Medicaid programs, these temporary expansions have been rapid and historic in scope, and will have substantial implications for patients, providers, payers, and federal/state financing. For policymakers, this temporary expansion may serve as a natural experiment for assessing which forms of telehealth services successfully expand access to care and should become permanent healthcare policy.
Medicare and Medicaid Flexibilities During Public Health Emergencies
This week, our In Focus comes from HMA Vice President Kathleen Nolan and Managing Principal Jon Blum. On March 13, 2020, President Trump declared a national emergency due to the rapid spread of COVID-19 virus. This declaration provides Health and Human Services (HHS) and the Centers of Medicare and Medicaid Services (CMS) new abilities to waive Medicare and Medicaid regulatory requirements to help health care providers, health plans and other stakeholders respond to immediate needs of their patients and communities. In the past, HHS and CMS have solicited requests for relief needs from states, local providers and trade associations, among other stakeholders. Health care providers, health plans and others should continue to monitor policy announcements from HHS and CMS and work with their states and trade associations to identify potential areas of need for requested regulatory relief.
HMA Analysis of the 2020 Medicare Advantage Annual Election Period
This week, our In Focus section examines Medicare Advantage (MA) enrollment changes resulting from the 2020 Annual Election Period (AEP). The AEP takes runs from October 15 to December 7 each year, and provides an opportunity for Medicare beneficiaries to sign up for, change, or disenroll from an MA plan for the upcoming year. The majority of enrollment changes occur during this period, but depending on beneficiary circumstances, additional opportunities may exist throughout the year to change coverage. Initial findings from the enrollment data suggest:
HMA Analysis of New Requirements Expanding Medicare Advantage Eligibility to Individuals with End-Stage Renal Disease
This week, our In Focus section comes from HMA Principal Eric Hammelman and Senior Consultant Narda Ipakchi. Today, Medicare beneficiaries with End-Stage Renal Disease (ESRD) are only eligible to enroll in Medicare Advantage (MA) plans if they select a MA Special Needs Plan (SNP) that specifically serves individuals with ESRD or develop ESRD while already enrolled in a MA plan. In 2018, approximately 121,000 MA enrollees (0.6 percent of the MA population) had diagnoses of ESRD, accounting for approximately 20 percent of the total Medicare ESRD population.[1] The 21st Century Cures Act, which was passed in 2016, included a provision that alters the eligibility and enrollment options for Medicare beneficiaries with ESRD. Starting in 2021, Medicare beneficiaries with ESRD will be able to enroll in any MA plan in their area. The Centers for Medicare & Medicaid Services (CMS) estimates MA enrollment of individuals with ESRD will nearly double to 242,000 in 2024, or approximately 41 percent of the total Medicare ESRD population.[2]
POTUS FY 2021 Budget: Summary of Medicare Provisions
This week, our In Focus section examines President Trump’s budget for fiscal year (FY) 2021. The budget includes a number of legislative and administrative proposals related to Medicare that are estimated to reduce net Medicare spending by $872 billion over the next ten years. It is important to note that the legislative proposals included in the President’s budget are non-binding and serve as recommendations to Congress where they may or may not be advanced. Under a Democratic-majority House of Representatives, many of the legislative proposals outlined in the FY 2021 budget are unlikely to advance. Administrative proposals are more likely to move forward, as the administration can implement these policies through its regulatory channels.
D-SNP 2021 Integration Requirements: Opportunities for Plans, States to Partner on Medicare-Medicaid Integration
This week, our In Focus section provides a high-level overview of the new Medicare Advantage Dual-Eligible Special Needs Plan (D-SNP) integration requirements in the Centers for Medicare & Medicaid Services (CMS) April 16, 2019, final rule[1] for calendar year (CY) 2021. CMS recently released two publications providing guidance and technical assistance to assist with the implementation of these new opportunities: the November 14, 2019, CMCS Informational Bulletin[2] and Integrated Care Resource Center technical assistance tool Sample Language for State Medicaid Agency Contracts with Dual Eligible Special Needs Plans.[3] Both identify steps to ensure that states’ Medicaid agency contracts (SMACs) with D-SNPs comply with the new 2021 requirements, and further encourage states and D-SNPs to work together to address the often fragmented care provided to the Medicare-Medicaid dually eligible population.
New Medicare Benefit: Opioid Use Disorder Treatment
This week, our In Focus section examines the new Medicare benefit for Opioid Use Disorder (OUD) treatment that includes counseling, as well as medication-assisted treatment (MAT) and related items and services. This benefit was established by Congress in the SUPPORT Act of 2018 and is now being implemented by the Centers for Medicare & Medicaid Services (CMS). Medicare beneficiaries, including those dually eligible for Medicare & Medicaid, are the fastest growing group of OUD patients. Beneficiaries may access one of two types of providers: Opioid Treatment Programs (OTPs) (i.e., methadone clinics), or physicians + other health professionals. Providers offering these services will receive a bundled payment, either weekly or monthly depending on the type of provider, that can repeat as long as a patient needs treatment. Based on early guidance, Medicare Advantage (MA) plans have already created 2020 benefit packages that provide a level of access to OTP services that is “consistent with prevailing community patterns of care.” Now that the new benefit is final, MA will need to cover both OTP & Physician OUD treatment for 2021.
HMA Medicare Experts in Demand
HMA Principal Mary Hsieh offered her expertise and insights during a panel discussion at the America’s Health Insurance Plans (AHIP) Conference. The panel, Blockbuster Medicare Innovations, focused on sweeping policy changes announced by the Centers for Medicaid and Medicare Services.
Preliminary Insights on 2020 Medicare Advantage and Part D Plan Offerings
This week, our In Focus section reviews the Medicare Advantage (MA) and Part D landscape files for the 2020 plan year released by the Centers for Medicare & Medicaid Services (CMS) on September 24, 2019. These files include information on MA and Part D offerings, including premiums and benefit design. This year’s release signals continued growth for the MA program in 2020. Nationwide, the number of MA plans continues to increase, with 3,144 offerings, up from 2,741 in 2019. Among these plans, 2,832 will offer Part D coverage. CMS states that the average monthly plan premium is expected to decrease 14 percent to $23.00 in 2020 down from $26.87 in 2019. According to CMS, this is the lowest average monthly premium since 2007.