This week, our In Focus section highlights changes that may affect the Centers for Medicare & Medicaid Services (CMS) Medicare Advantage Star Rating program and how these changes impact future summary Part C & D Star Rating scores. As the CMS Medicare Advantage Star Rating program continues evolving from year to year, many plans have yet to achieve at least four star status, and therefore are missing out on additional Medicare revenues. The Star Rating landscape is expected to change drastically over the next two years for plans due to CMS’ continued focus on phasing-in greater reliance on outcomes measures and measures of care experience, rather than process measures. As a result, many plans are at risk of losing their four star overall rating and underperforming plans could be at risk of receiving a low performance indicator.
Medicare
Health Management Associates Provides Updates in 2021 Federal Healthcare Policy Landscape
This week, our In Focus comes from an HMA cross-cutting subject matter team, who have updated a core set of federal policy slides that analyzes recent federal policy actions following the Presidential and Congressional elections. It includes an analysis of President Biden’s $1.9 trillion COVID-19 relief legislation currently in development and recent CMS regulatory and administrative actions. Specifically, the analysis looks at:
The Centers for Medicare & Medicaid Services Innovation Center’s Geographic Direct Contracting Model Opportunity
This week, our In Focus section reviews a new model – Geographic Direct Contracting – introduced by the Centers for Medicare & Medicaid Services (CMS) Innovation Center. The model will test whether a geographic-based approach to care delivery and value-based care can improve health and reduce costs for Medicare beneficiaries enrolled in the traditional fee-for-service program across an entire region. This model represents one of the most transformational models released by the Innovation Center. During the 6-year Geographic Direct Contracting model performance period the traditional Medicare program will be replaced by the Direct Contracting program in the 10 selected regions.
Commonwealth Fund Blog Post Highlights Medicare Changes Related to COVID-19
Jennifer Podulka penned a blog post for The Commonwealth Fund in conjunction with The SCAN Foundation, highlighting the legislative and regulatory changes made to Medicare in response to the COVID-19 pandemic. She was part of the HMA team who authored an Issue Brief and policy tracker earlier this year.
Drivers and Barriers to Adoption of Flexible Medicare Advantage Supplemental Benefits
This week’s In Focus highlights a recent HMA publication examining the drivers and barriers to Medicare Advantage plan adoption of newly available supplemental benefits intended to address unmet health and social needs. Unlike Traditional Medicare, Medicare Advantage plans, which provide coverage for 40 percent of all Medicare beneficiaries, may offer enrollees supplemental benefits which are not covered by the Medicare program. Until recently, the Medicare program has required that supplemental benefits be limited to those that are medical in nature. However, in recent years, Congress and CMS —through four different legislative and regulatory authorities — granted new flexibilities for Medicare Advantage plans to offer non-medical benefits that address social needs. Medicare Advantage plans may also now tailor supplemental benefits and make them available only to certain subpopulations based on chronic disease or health status.
Report Examines Medicare Advantage Supplemental Benefits
The experts at Health Management Associates (HMA) have released Medicare Advantage Supplemental Benefit Flexibilities: An Early Assessment of Adoption and Policy Opportunities for Expanded Access. The white paper examines the factors contributing to a Medicare Advantage plan’s decision to offer or not offer newly available supplemental benefits and opportunities and challenges with adoption and implementation. Newly available supplemental benefits are intended to address unmet health and social needs.
2020 In Review: Top Medicare-Medicaid Integration Trends and Policies
This week, our In Focus section focuses on five critical policy and program trends to provide integrated care to dual-eligible individuals for Medicare and Medicaid. Both federal and state governments continue to look for ways to improve coordination and integration for this population. We anticipate the emphasis on innovative approaches to whole person, person-centered care, care management and coordination, care transitions, and regulatory oversight to persist. 2020 has been an active year of policymaking by the Centers for Medicare & Medicaid Services (CMS) and states. HMA distilled the themes and their strategic implications in this article. We continue to assist clients in tracking new policies and industry trends, developing innovative plans and strategies, and delivering high quality care and services to this population.
CMS Finalizes Meaningful Expansions of Medicare Telehealth Service Coverage Through 2021
This week, our In Focus section reviews the finalized coverage expansions for Medicare telehealth services in the Centers for Medicare & Medicaid Services (CMS) Calendar Year (CY) 2021 Physician Fee Schedule (PFS) Final Rule. Telehealth advocates will be pleased to see meaningful expansions; however, the response of advocates will also be tempered by the impending return of the geographic and site of service limitations that will follow at the conclusion of the COVID-19 Public Health Emergency (PHE). During the PHE, millions of patients and providers increased their use of telehealth services to expand access to care. Given this shift in the delivery of care, telehealth advocates had been hopeful CMS would make extensive permanent coverage expansions in the Medicare program. In light of this, CMS’s new regulation will come as a reminder to many that the key to long term expansions of Medicare telehealth coverage lies in the hands of the U.S. Congress.
CMS Introduces New Medicare Direct Contracting Model Opportunity
This week, our In Focus section looks at a new Medicare model, Direct Contracting, introduced by the Centers for Medicare & Medicaid Services (CMS) Innovation Center. The new model will build on and continue testing potential reforms to the Medicare program encompassed by accountable care organizations (ACOs), Medicare Advantage (MA), and private sector risk-sharing arrangements. The payment model options may appeal to a broad range of physician and provider groups and other organizations because they are expected to introduce flexibility in health care delivery, support a focus on beneficiaries with complex, chronic conditions, and encourage participation from organizations that have not typically participated in traditional fee-for-service (FFS) Medicare or CMS Innovation Center models. However, there will be substantial financial risk—and reward—for participants based on a new, complex methodology, so organizations interested in this new model should carefully consider the possible outcomes from participating in Direct Contracting versus other options. CMS has announced that 51 organizations will participate in the model’s trial Implementation Period, which runs from October 1, 2020, through March 31, 2021. The agency has stated that it expects to announce additional Direct Contracting pathways in the future and that the next round of applications for participation in the second performance year will open in early 2021.
A Short-Term Path to Avoid ACA Uncertainty as the Pandemic Continues
In this week’s In Focus section, Health Management Associates (HMA) Managing Director MMS Matt Powers, Senior Consultant Kaitlyn Feiock, and Regional Vice President Kathleen Nolan look at the future of the Patient Protection and Affordable Care Act (ACA). On November 10, 2020, the Supreme Court of the United States (SCOTUS) heard oral arguments for California v. Texas, challenging the constitutionality and severability of the ACA. This challenge became possible after the 2017 Tax Cuts and Jobs Act, which zeroed out the individual mandate penalty for not purchasing health insurance. While most experts agree that an entire invalidation of the ACA is the least likely outcome based on the oral arguments, some uncertainty remains and more than $100 billion federal funds are at risk. The ACA standardized insurance rules offset premium costs for many individual market consumers and provided authority and funding for Medicaid Expansions in the overwhelming majority of states. The ACA also included other provisions that may be at risk but are not the subject of this note, such as the creation of Center for Medicare and Medicaid Innovation (CMMI) and the Medicare-Medicaid Coordination Office, as well as demonstration authority that has led to the creation of numerous coverage models. As states, Congress, and the federal executive branch face the possibility that the ACA may not survive in its present form, what mitigation strategies are available at the state and federal levels to stabilize uncertainties and protect against abrupt coverage changes?