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This week our In Focus section reviews the Centers for Medicare and Medicaid Services’ (CMS) announcement of initial guidance for the new Medicare Drug Price Negotiation Program for 2026. This initial guidance is one of many steps CMS described in the Medicare Drug Price Negotiation Program timeline for the first year of negotiation.
The Drug Price Negotiation Program was approved as part of the Inflation Reduction Act (IRA) (P.L. 117- 169) in August 2022. As discussed in our previous In Focus, the IRA includes several other policies aimed at addressing cost, affordability and access to prescription drugs within the Medicare program.
The Drug Negotiation Program allows the U.S. Department of Health and Human Services (HHS) to negotiate maximum fair prices (MFPs) for Part D drugs. Negotiations between HHS and prescription drug manufactures will begin in 2023 and continue into 2024 before negotiated prices go into effect Jan. 1, 2026.
For Medicare payment in 2026, HHS can negotiate prices for up to 10 Part D drugs that do not have generic or biosimilar competition. CMS can increase the number of Part D drugs selected for price negotiation each subsequent year. Starting in 2028, the agency can annually add up to 20 new Part B or Part D drugs to the program.
The published guidance describes CMS’ approach for identifying the drugs selected for the initial year of the program. However, CMS is finalizing these policies as announced for the initial drug negotiation year.
The initial guidance also details the requirements and procedures for implementing the process for the first set of negotiations. For example, the guidance details aspects related to the offer-counter-offer exchange process, confidentiality terms following an agreement, penalties for violations, and the dispute resolution process.
Key Considerations
The drug negotiation program presents numerous operational and policy questions for CMS, manufacturers, and the healthcare sector broadly. The program is expected to have a direct impact on prices and affordability for the Medicare program and its beneficiaries. Additionally, other public and commercial payers will want to consider the potential downstream impacts on their costs. Ongoing monitoring of HHS’ implantation of the drug negotiation program and the pharmaceutical industry’s response to the drug negotiation program will help health plans, providers, and other interested stakeholders navigate this new landscape.
What’s Next
In the short-run, CMS will benefit from feedback from stakeholders about the outstanding policy and operational issues the agency has identified. Comments can be submitted until April 14, 2023
CMS anticipates issuing revised guidance for the first year of negotiation in Summer 2023. By September 1, 2023, CMS plans to publish the first 10 Part D drugs selected for the initial program year. The negotiated maximum fair prices for these drugs will be published by September 1, 2024 and prices will be in effect starting January 1, 2026.
HMA and HMA companies will continue to analyze this and subsequent guidance. We have analytical capabilities and expertise to assist with tailored analysis for manufacturers, providers, patient groups, health plans, and other stakeholders. HMA has the ability to model policy impacts of the drug negotiation program, support the drafting of feedback to CMS as the program is designed and implemented, and provide technical assistance in considering how this new program may interact with other Medicare and Medicaid initiatives.
If you have questions about the Drug Negotiation Program or other aspects of the Inflation Reduction Act and how it will affect manufacturers, Medicare providers, Medicaid programs and patients, contact Kevin Kirby (kmkirby@themorancompany.com), Amy Bassano (abassano@healthmanagement.com) or Andrea Maresca (amaresca@healthmanagement.com).
HMA has valued recent opportunities to support public health departments to collaborate with communities working to identify and address root causes and ultimately reduce maternal and infant mortality and racial disparities in birth outcomes in Delaware and Maryland.
In partnership with the Delaware Department of Health and Social Services’ Division of Public Health, HMA is in its fourth year of administering a mini-grant program and providing backbone services to community-based organizations. These entities provide wraparound services and a variety of other supports to pregnant and parenting people and their families, with the goal of improving maternal and infant health and reducing racial disparities. We also lead a collective impact evaluation of the programs, working closely with the participating organizations to help them build their capacity to collect and analyze data, developing interim and annual reports, and providing frequent updates to the Division of Public Health and other stakeholders in the state that are collaborating to improve health and wellbeing. HMA provides fiscal and administrative oversight, coaching and evaluation, and convenes the participating organizations for quarterly learning collaboratives, which have contributed to stronger relationships and collaboration among the mini-grantees. In addition, we are implementing and evaluating a guaranteed basic income program as part of the Social Determinants of Health committee of the Delaware Healthy Maternal Infant Consortium (DHMIC). This project is a long-term commitment to collaborating with community-based organizations to build their capacity to address racial disparities and support their work, which is driven by the needs of the people they serve and know best. Grantees are selected through a streamlined process with low administrative burden, prioritizing community input on needed services. Through a collective impact evaluation, the participating organizations are finding positive effects on the self-reported health and wellbeing of program participants.
Launch of the first cohort of Healthy Women Healthy Babies Zones Mini-grantees in 2019. Photo Credit: Division of Public Health – Delaware Health and Social Services
With the Frederick County, Maryland Health Department, HMA conducted a study in 2022 using a community-based participatory research (CBPR) approach to understand and articulate drivers of maternal and infant health disparities experienced by Black women in Frederick County. In collaboration with the health department and newly formed Community Advisory Board (CAB), we facilitated a series of in-person retreats to: collect, analyze, and share quantitative and qualitative data regarding disparities and the drivers of those disparities with stakeholders; understand the data and the story behind the health disparity numbers; and develop and deploy additional research methods, such as surveys, key informant interviews, and focus groups, to further explore the lived experience of Black Frederick County mothers. This iterative approach to conducting mixed-methods research uses the CBPR framework to ensure sustained and meaningful community engagement from project start to end. HMA also developed a driver diagram to illustrate how the root cause, systemic racism, directly influences other drivers of Black maternal health disparities such as historic disinvestment in Black maternal health, historical trauma navigating healthcare, low social capital, health insurance availability, and a perceived lack of emotional and physical safety in clinical settings. The diagram will be shared with relevant stakeholders and inform next steps.
In our reproductive health-related work, HMA has guided groups through decision-making processes, with transparency and without bias, and we understand the importance of group dynamics. Bringing decades of real-world public policy and community and key stakeholder facilitation experience, HMA collaborates with a variety of stakeholders and community members to develop and implement public policy at the local and state levels, as well as to evaluate these efforts. Our experience ranges from national, state, and county agencies, to private sector and community-based organizations that partner with governments to implement policy. Our team has extensive experience working with and within organizations to facilitate discussions, listen to and build consensus across sectors, develop strategic plans, and bring diverse perspectives together to promote health and wellness for communities.
As part of recognizing Women’s History Month, HMA colleagues reflected on recent work to support maternal and infant health and reduce racial disparities in birth outcomes in collaboration with health departments and communities in Delaware and Maryland. More information on our recent projects supporting reproductive health can be found here.
HMA to Host Webinar on Approaches to Implementing Medicaid Demonstration Programs
On January 26, the Centers for Medicare & Medicaid Services (CMS) approved California’s (CA) section 1115 request to cover targeted healthcare services for incarcerated individuals 90 days before release. This historical partial rollback of the Medicaid Inmate Exclusion Policy empowers the CA Department of Health Care Services (DHCS) to collaborate with state agencies, counties, health plans and community-based organizations to create coordinated community reentry services focused on persons transitioning from incarceration to community that provide physical and behavioral healthcare services.
Fourteen states have pending section 1115 demonstration requests to provide specific healthcare services for justice-involved individuals. CMS has indicated it will be issuing guidance on the coverage parameters for healthcare services for individuals transitioning from carceral settings. These efforts allow states, counties, and cities to build coordinated systems of healthcare care to support reentry. Building such systems requires infrastructure development and enhancement, stakeholder engagement, strategic planning, and project and change management across justice partners, health plans, and community-based organizations.
Implementing the services will involve an in-depth understanding of the fundamental healthcare needs of justice-involved individuals, carceral setting healthcare delivery and reentry (transition to the community), and how to operationalize necessary changes to meet program requirements. Additionally, change management, critical stakeholder coordination, infrastructure, and technology development, enhancement, guidance on data-sharing agreements, and health plan involvement will need to be created or adapted to meet the CMS 1115 requirements. Administrators of carceral settings and correctional healthcare providers must coordinate services with community-based organizations and health plans to implement timely, cost-effective, and quality healthcare services to individuals leaving carceral facilities.
States, payors, correctional administrators, and healthcare providers will benefit from understanding the 1115 requirements to stand up this initiative, recommendations to facilitate the 1115 application process, how it intersects with healthcare delivery within a carceral setting and during reentry, and practical strategies for planning and operationalizing the effective delivery and coordination of healthcare services that meet program requirements.
On Thursday, April 6 at 2 pm ET/11 am PT join HMA for a webinar that will help states and other stakeholders understand the section 1115 parameters and provide insight to states, local government, correctional health settings, and providers on how to best plan for implementing such services.
Key experts will cover the following topics:
Deep Dive into California’s section 1115 approval and lessons learned from the California application process?
Operationalizing In Reach and Re-entry Programming for Justice-Involved Individuals
Understanding the complex needs of justice-involved individuals.
What investments must states make to implement Medicaid-eligible services for justice-involved individuals?
What role can technology and digital health play in supplementing direct care?
The Role of Payers in new Services for Justice-Involved Individuals
HMA consultants bring unparalleled expertise in Medicaid policy, correctional health and a deep understanding of the unique needs of this population. We have the operational knowledge and experience with technology and digital health solutions, as well as the needed data and analytic capacity to collect the correct data to drive improvements in equity and access to care.
This week, our In Focus section reviews recent Medicaid enrollment trends in capitated, risk-based managed care in 32 states.[1] Many state Medicaid agencies post monthly enrollment figures by health plan for their Medicaid managed care population to their websites. This data allows for the timeliest analysis of enrollment trends across states and managed care organizations. All 32 states highlighted in this review have released monthly Medicaid managed care enrollment data into the fourth quarter (Q4) of 2022. This report reflects the most recent data posted. HMA will continue tracking enrollment throughout the eligibility redetermination period. HMA has made the following observations related to the enrollment data shown on Table 1 (below):
The 32 states in this report account for an estimated 71 million Medicaid managed care enrollees as of December 2022. Based on HMA estimates of MCO enrollment in states not covered in this report, we believe that nationwide Medicaid MCO enrollment was likely about 75 million in December 2022. As such, the enrollment data across these 32 states represents approximately 95 percent of all Medicaid MCO enrollment.
Across the 32 states tracked in this report, Medicaid managed care enrollment is up 7.5 percent year-over-year as of December 2022.
All states, besides Mississippi, saw increases in enrollment in December 2022, compared to the previous year, due to the gains from the COVID-19 pandemic. Mississippi Medicaid managed care enrollment fell because the state shifted members to FFS during the public health emergency.
Twenty-three of the 32 states – Arizona, California, District of Columbia, Illinois, Indiana, Iowa, Kentucky, Louisiana, Maryland, Michigan, Minnesota, Missouri, Nebraska, Nevada, New Jersey, New Mexico, New York, Ohio, Oregon, Pennsylvania, Virginia, Washington, and West Virginia – expanded Medicaid under the Affordable Care Act and have seen increased Medicaid managed care enrollment since expansion.
The 23 expansion states listed above have seen net Medicaid managed care enrollment increase by 3.5 million members, or 7.2 percent, in the past year, to 52.2 million members at the end of 2022.
The nine states that have not yet expanded Medicaid as of December 2022 – Florida, Georgia, Kansas, Mississippi, North Carolina, South Carolina, Tennessee, Texas, and Wisconsin – have seen Medicaid managed care enrollment increase 8.3 percent to 19 million members at the end of 2022.
Table 1 – Monthly MCO Enrollment by State – July 2022 through December 2022
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Arizona
2,069,048
2,079,360
2,095,101
2,106,800
2,116,444
2,127,666
+/- m/m
8,527
10,312
15,741
11,699
9,644
11,222
% y/y
7.6%
0.0%
7.5%
7.4%
7.2%
7.1%
California
12,929,500
13,013,324
13,073,427
13,132,616
13,231,993
13,204,398
+/- m/m
215,506
83,824
60,103
59,189
99,377
(27,595)
% y/y
9.8%
9.9%
9.9%
9.9%
10.2%
9.5%
D.C.
246,957
247,704
248,577
249,617
250,676
+/- m/m
3,223
747
873
1,040
1,059
N/A
% y/y
6.7%
6.7%
6.5%
6.5%
6.4%
Florida
4,385,965
4,432,233
4,465,670
4,502,297
4,537,121
4,581,266
+/- m/m
41,441
46,268
33,437
36,627
34,824
44,145
% y/y
10.9%
10.9%
10.7%
10.7%
10.7%
11.0%
Georgia
1,975,277
1,988,727
2,016,462
2,027,275
2,035,673
+/- m/m
13,117
13,450
N/A
N/A
10,813
8,398
% y/y
9.8%
9.5%
9.0%
8.7%
8.3%
Illinois
2,890,332
2,884,029
2,900,232
2,929,584
2,965,007
3,000,717
+/- m/m
(8,672)
(6,303)
16,203
29,352
35,423
35,710
% y/y
5.1%
4.5%
4.1%
4.4%
5.1%
5.5%
Indiana
1,742,762
1,761,692
1,769,400
1,781,464
1,797,451
1,813,044
+/- m/m
6,906
18,930
7,708
12,064
15,987
15,593
% y/y
11.6%
11.3%
11.0%
10.5%
10.2%
10.3%
Iowa
795,534
799,748
807,296
812,481
814,490
+/- m/m
2,642
4,214
7,548
N/A
N/A
2,009
% y/y
5.9%
5.8%
6.4%
6.0%
6.1%
Kansas
489,309
490,911
492,640
497,257
499,143
500,814
+/- m/m
2,691
1,602
1,729
4,617
1,886
1,671
% y/y
N/A
N/A
N/A
N/A
8.3%
6.3%
Kentucky
1,494,068
1,487,387
1,509,274
1,518,906
1,528,484
1,534,657
+/- m/m
6,069
(6,681)
21,887
9,632
9,578
6,173
% y/y
5.5%
5.3%
5.6%
5.8%
6.7%
6.1%
Louisiana
1,821,644
1,828,015
1,833,457
1,841,693
1,858,092
1,860,170
+/- m/m
7,213
6,371
5,442
8,236
16,399
2,078
% y/y
4.6%
4.5%
4.4%
4.7%
5.2%
5.8%
Maryland
1,496,677
1,502,271
1,508,469
1,514,381
1,521,171
1,529,308
+/- m/m
8,205
5,594
6,198
5,912
6,790
8,137
% y/y
6.5%
6.2%
6.1%
5.8%
5.8%
5.7%
Michigan
2,280,243
2,294,432
2,299,913
2,309,913
2,319,951
2,324,046
+/- m/m
2,923
14,189
5,481
10,000
10,038
4,095
% y/y
3.8%
3.6%
3.5%
3.7%
4.5%
4.3%
Minnesota
1,261,112
1,262,073
1,278,954
1,286,890
1,293,858
1,299,194
+/- m/m
1,893
961
16,881
7,936
6,968
5,336
% y/y
7.3%
6.7%
7.4%
7.5%
7.5%
7.5%
Mississippi
367,137
363,387
364,612
355,694
367,902
396,880
+/- m/m
(452)
(3,750)
1,225
(8,918)
12,208
28,978
% y/y
-22.7%
-19.9%
-17.4%
-17.3%
-12.5%
-3.9%
Missouri
1,038,239
1,065,217
1,099,707
1,118,373
1,136,589
1,157,005
+/- m/m
26,520
26,978
34,490
18,666
18,216
20,416
% y/y
27.0%
29.1%
32.6%
31.7%
31.8%
29.0%
Nebraska
363,328
366,202
369,770
372,613
374,857
378,237
+/- m/m
2,740
2,874
3,568
2,843
2,244
3,380
% y/y
12.4%
11.9%
11.7%
11.2%
10.8%
10.6%
Nevada
687,362
689,139
697,752
675,465
685,736
692,890
+/- m/m
9,464
1,777
8,613
(22,287)
10,271
7,154
% y/y
9.3%
9.0%
9.3%
4.2%
5.2%
5.7%
New Jersey
2,100,947
2,113,930
2,125,181
2,130,868
2,144,514
2,158,966
+/- m/m
10,897
12,983
11,251
5,687
13,646
14,452
% y/y
7.4%
7.4%
7.2%
7.0%
7.1%
7.0%
New Mexico
809,991
811,732
812,995
813,630
814,466
815,798
+/- m/m
2,491
1,741
1,263
635
836
1,332
% y/y
4.2%
3.7%
3.4%
3.0%
2.6%
2.3%
New York
5,855,615
5,853,108
5,878,519
5,906,264
5,929,288
5,961,782
+/- m/m
39,970
(2,507)
25,411
27,745
23,024
32,494
% y/y
4.5%
4.3%
4.2%
4.3%
4.5%
4.6%
North Carolina
1,738,545
1,746,948
1,757,503
1,768,974
1,778,199
1,837,423
+/- m/m
9,047
8,403
10,555
11,471
9,225
59,224
% y/y
8.0%
6.8%
6.7%
6.6%
6.6%
9.5%
Ohio
2,964,731
2,963,616
2,960,922
2,958,666
2,961,983
2,973,763
+/- m/m
(1,340)
(1,115)
(2,694)
(2,256)
3,317
11,780
% y/y
3.4%
2.6%
1.9%
1.4%
1.0%
0.9%
Oregon
1,193,358
1,202,198
1,206,520
1,211,099
1,221,435
1,228,054
+/- m/m
3,920
8,840
4,322
4,579
10,336
6,619
% y/y
8.3%
8.4%
7.7%
7.6%
7.4%
7.2%
Pennsylvania
2,895,837
2,909,985
2,920,584
2,937,049
2,950,613
2,966,207
+/- m/m
13,973
14,148
10,599
16,465
13,564
15,594
% y/y
7.4%
7.3%
6.9%
6.8%
6.6%
6.5%
South Carolina
1,055,785
1,063,445
1,069,569
1,078,094
1,084,529
1,089,577
+/- m/m
5,226
7,660
6,124
8,525
6,435
5,048
% y/y
7.6%
7.5%
7.4%
7.9%
7.6%
7.5%
Tennessee
1,692,395
1,704,398
1,710,125
1,718,539
1,726,603
1,734,108
+/- m/m
6,737
12,003
5,727
8,414
8,064
7,505
% y/y
6.0%
6.1%
6.1%
6.0%
5.9%
5.8%
Texas
5,466,045
5,653,169
+/- m/m
N/A
N/A
N/A
N/A
N/A
N/A
% y/y
8.6%
10.6%
Virginia
1,572,923
1,582,973
1,589,722
1,598,875
1,608,840
1,619,311
+/- m/m
11,829
10,050
6,749
9,153
9,965
10,471
% y/y
11.3%
11.0%
10.0%
9.6%
10.1%
9.8%
Washington
1,884,734
1,898,983
1,904,127
1,913,230
1,927,690
1,959,278
+/- m/m
8,867
14,249
5,144
9,103
14,460
31,588
% y/y
#DIV/0!
#DIV/0!
5.8%
5.9%
6.0%
7.2%
West Virginia
519,992
524,042
524,922
527,226
530,494
533,194
+/- m/m
2,871
4,050
880
2,304
3,268
2,700
% y/y
6.5%
6.8%
6.4%
5.9%
5.9%
5.7%
Wisconsin
1,161,202
1,166,208
1,172,719
1,179,204
1,184,899
1,190,673
+/- m/m
5,263
5,006
6,511
6,485
5,695
5,774
% y/y
7.5%
7.2%
7.1%
7.1%
6.9%
6.6%
Note: In Table 1 above and the state tables below, “+/- m/m” refers to the enrollment change from the previous month. “% y/y” refers to the percentage change in enrollment from the same month in the previous year.
Below, we provide a state-specific analysis of recent enrollment trends in the states where HMA tracks data.
It is important to note the limitations of the data presented. First, not all states report the data at the same time during the month. Some of these figures reflect beginning-of-the-month totals, while others reflect an end-of-the-month snapshot. Second, in some cases the data is comprehensive in that it covers all state-sponsored health programs for which the state offers managed care; in other cases, the data reflects only a subset of the broader Medicaid managed care population. This is the key limiting factor in comparing the data described below and figures reported by publicly traded Medicaid MCOs. Consequently, the data we review in Table 1 and throughout the In Focus section should be viewed as a sampling of enrollment trends across these states rather than a comprehensive comparison, which cannot be developed based on publicly available monthly enrollment data.
State-Specific Analysis
Arizona
Medicaid Expansion Status: Expanded January 1, 2014
Enrollment in Arizona’s two Medicaid managed care programs grew to 2.1 million in December 2022, up 7.1 percent from December 2021.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Acute Care
2,002,584
2,012,802
2,028,335
2,039,880
2,049,311
2,060,376
ALTCS
66,464
66,558
66,766
66,920
67,133
67,290
Total Arizona
2,069,048
2,079,360
2,095,101
2,106,800
2,116,444
2,127,666
+/- m/m
8,527
10,312
15,741
11,699
9,644
11,222
% y/y
7.6%
7.5%
7.4%
7.2%
7.1%
California
Medicaid Expansion Status: Expanded January 1, 2014
Medi-Cal managed care enrollment was up 9.5 percent year-over-year to 13.2 million, as of December 2022.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Two-Plan Counties
8,356,137
8,409,817
8,446,514
8,481,885
8,548,096
8,588,418
Imperial/San Benito
100,384
101,117
101,633
102,064
102,881
103,437
Regional Model
364,066
366,437
368,624
370,361
373,402
375,473
GMC Counties
1,435,250
1,445,532
1,452,127
1,458,149
1,470,122
1,391,421
COHS Counties
2,561,831
2,578,747
2,593,003
2,608,731
2,625,795
2,634,112
Duals Demonstration
111,832
111,674
111,526
111,426
111,697
111,537
Total California
12,929,500
13,013,324
13,073,427
13,132,616
13,231,993
13,204,398
+/- m/m
215,506
83,824
60,103
59,189
99,377
(27,595)
% y/y
9.8%
9.9%
9.9%
9.9%
10.2%
9.5%
District of Columbia
Medicaid Expansion Status: Expanded January 1, 2014
Medicaid managed care enrollment in the District of Columbia was up 6.4 percent to almost 251,000 in November 2022.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Total District of Columbia
246,957
247,704
248,577
249,617
250,676
+/- m/m
3,223
747
873
1,040
1,059
% y/y
6.7%
6.7%
6.5%
6.5%
6.4%
Florida
Medicaid Expansion Status: Not Expanded
Florida’s statewide Medicaid managed care program had seen an 11 percent rise in total covered lives over the last year to nearly 4.6 million beneficiaries as of December 2022. (Note that the managed LTC enrollment figures listed below are a subset of the Managed Medical Assistance (MMA) enrollments and are included in the MMA number; they are not separately added to the total to avoid double counting).
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
MMA
3,908,539
3,948,929
3,978,098
4,010,534
4,041,816
4,080,381
LTC (Subset of MMA)
124,107
124,691
125,397
126,144
126,720
126,621
SMMC Specialty Plan
332,179
338,057
342,325
346,516
350,058
355,638
FL Healthy Kids
145,247
145,247
145,247
145,247
145,247
145,247
Total Florida
4,385,965
4,432,233
4,465,670
4,502,297
4,537,121
4,581,266
+/- m/m
41,441
46,268
33,437
36,627
34,824
44,145
% y/y
10.9%
10.9%
10.7%
10.7%
10.7%
11.0%
Georgia
Medicaid Expansion Status: Not Expanded
As of December 2022, Georgia’s Medicaid managed care program covered more than 2 million members, up 8.3 percent from the previous year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total Georgia
1,975,277
1,988,727
2,016,462
2,027,275
2,035,673
+/- m/m
13,117
13,450
10,813
8,398
% y/y
9.8%
9.5%
9.0%
8.7%
8.3%
Illinois
Medicaid Expansion Status: Expanded January 1, 2014
Illinois enrollment across the state’s managed care programs was up 5.5 percent to 3 million as of December 2022.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
HealthChoice
2,800,420
2,793,124
2,809,689
2,839,342
2,874,700
2,909,303
Duals Demonstration
89,912
90,905
90,543
90,242
90,307
91,414
Total Illinois
2,890,332
2,884,029
2,900,232
2,929,584
2,965,007
3,000,717
+/- m/m
(8,672)
(6,303)
16,203
29,352
35,423
35,710
% y/y
5.1%
4.5%
4.1%
4.4%
5.1%
5.5%
Indiana
Medicaid Expansion Status: Expanded in 2015 through HIP 2.0
As of December 2022, enrollment in Indiana’s managed care programs—Hoosier Healthwise, Hoosier Care Connect, and Healthy Indiana Program (HIP)—was more than 1.8 million, up 10.3 percent from the previous year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Hoosier Healthwise
845,910
852,904
857,952
863,973
869,613
876,606
Hoosier Care Connect
102,805
102,819
102,537
102,253
102,200
102,150
HIP
794,047
805,969
808,911
815,238
825,638
834,288
Indiana Total
1,742,762
1,761,692
1,769,400
1,781,464
1,797,451
1,813,044
+/- m/m
6,906
18,930
7,708
12,064
15,987
15,593
% y/y
11.6%
11.3%
11.0%
10.5%
10.2%
10.3%
Iowa
Medicaid Expansion Status: Expanded January 1, 2014
Iowa launched its statewide Medicaid managed care program in April of 2016. Enrollment across all populations was nearly 814,500, as of December 2022. Enrollment was up 6.1 percent from the previous year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Traditional Medicaid
507,266
510,618
516,556
520,234
521,118
Iowa Wellness Plan
237,910
239,261
242,555
244,724
246,385
hawk-i
50,358
49,869
48,185
47,523
46,987
Total Iowa
795,534
799,748
807,296
812,481
814,490
+/- m/m
2,642
4,214
7,548
2,009
% y/y
5.9%
5.8%
6.4%
6.0%
6.1%
Kansas
Medicaid Expansion Status: Not Expanded
Kansas Medicaid managed care enrollment was nearly 501,000 as of December 2022, up 6.3 percent from the previous year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total Kansas
489,309
490,911
492,640
497,257
499,143
500,814
+/- m/m
2,691
1,602
1,729
4,617
1,886
1,671
% y/y
8.3%
6.3%
Kentucky
Medicaid Expansion Status: Expanded January 1, 2014
As of December 2022, Kentucky covered more than 1.5 million beneficiaries in risk-based managed care. Total enrollment was up 6.1 percent from the prior year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total Kentucky
1,494,068
1,487,387
1,509,274
1,518,906
1,528,484
1,534,657
+/- m/m
6,069
(6,681)
21,887
9,632
9,578
6,173
% y/y
5.5%
5.3%
5.6%
5.8%
6.7%
6.1%
Louisiana
Medicaid Expansion Status: Expanded July 1, 2016
Medicaid managed care enrollment in Louisiana was more than 1.86 million as of December 2022, up 5.8 percent from the previous year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total Louisiana
1,821,644
1,828,015
1,833,457
1,841,693
1,858,092
1,860,170
+/- m/m
7,213
6,371
5,442
8,236
16,399
2,078
% y/y
4.6%
4.5%
4.4%
4.7%
5.2%
5.8%
Maryland
Medicaid Expansion Status: Expanded January 1, 2014
Maryland’s Medicaid managed care program covered more than 1.5 million lives as of December 2022.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total Maryland
1,496,677
1,502,271
1,508,469
1,514,381
1,521,171
1,529,308
+/- m/m
8,205
5,594
6,198
5,912
6,790
8,137
% y/y
6.5%
6.2%
6.1%
5.8%
5.8%
5.7%
Michigan
Medicaid Expansion Status: Expanded April 1, 2014
As of December 2022, Michigan’s Medicaid managed care was up 4.3 percent to 2.3 million.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Medicaid
2,239,937
2,251,810
2,256,800
2,265,219
2,274,763
2,279,473
MI Health Link (Duals)
40,306
42,622
43,113
44,694
45,188
44,573
Total Michigan
2,280,243
2,294,432
2,299,913
2,309,913
2,319,951
2,324,046
+/- m/m
2,923
14,189
5,481
10,000
10,038
4,095
% y/y
3.8%
3.6%
3.5%
3.7%
4.5%
4.3%
Minnesota
Medicaid Expansion Status: Expanded January 1, 2014
As of December 2022, enrollment across Minnesota’s multiple managed Medicaid programs was nearly 1.3 million, up 7.5 percent from the prior year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Parents/Kids
748,197
748,513
758,100
763,044
767,798
770,918
Expansion Adults
272,666
273,387
278,421
281,284
284,073
288,680
Senior Care Plus
24,190
24,252
25,344
25,914
26,415
26,740
Senior Health Options
43,429
43,686
43,920
44,162
44,248
44,324
Special Needs BasicCare
64,656
64,484
65,562
65,763
65,987
66,171
Moving Home Minnesota
11
11
10
10
9
11
Minnesota Care
107,963
107,740
107,597
106,713
105,328
102,350
Total Minnesota
1,261,112
1,262,073
1,278,954
1,286,890
1,293,858
1,299,194
+/- m/m
1,893
961
16,881
7,936
6,968
5,336
% y/y
7.3%
6.7%
7.4%
7.5%
7.5%
7.5%
Mississippi
Medicaid Expansion Status: Not Expanded
MississippiCAN, the state’s Medicaid managed care program, had membership down 3.9 percent to nearly 397,000 as of December 2022.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total Mississippi
367,137
363,387
364,612
355,694
367,902
396,880
+/- m/m
(452)
(3,750)
1,225
(8,918)
12,208
28,978
% y/y
-22.7%
-19.9%
-17.4%
-17.3%
-12.5%
-3.9%
Missouri
Medicaid Expansion Status: Expansion Enrollment began in October 2021
Missouri managed care enrollment in the Medicaid and CHIP programs was nearly 1.2 million in December 2022.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total Medicaid
758,928
757,312
769,419
775,076
782,863
787,611
Total CHIP
28,949
28,937
29,026
29,121
29,231
29,402
Total AEG
199,963
228,361
250,131
262,612
272,574
287,692
Total SHK
50,399
50,607
51,131
51,564
51,921
52,300
Total Missouri
1,038,239
1,065,217
1,099,707
1,118,373
1,136,589
1,157,005
+/- m/m
26,520
26,978
34,490
18,666
18,216
20,416
% y/y
27.0%
29.1%
32.6%
31.7%
31.8%
29.0%
Nebraska
Medicaid Expansion Status: Expanded October 1, 2020
As of December 2022, Nebraska’s Medicaid managed care program enrolled 378,000 members, up 10.6 percent from the previous year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total Nebraska
363,328
366,202
369,770
372,613
374,857
378,237
+/- m/m
2,740
2,874
3,568
2,843
2,244
3,380
% y/y
12.4%
11.9%
11.7%
11.2%
10.8%
10.6%
Nevada
Medicaid Expansion Status: Expanded January 1, 2014
Nevada’s Medicaid managed care enrollment was up 5.7 percent to nearly 693,000 as of December 2022.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total Nevada
687,362
689,139
697,752
675,465
685,736
692,890
+/- m/m
9,464
1,777
8,613
(22,287)
10,271
7,154
% y/y
9.3%
9.0%
9.3%
4.2%
5.2%
5.7%
New Jersey
Medicaid Expansion Status: Expanded January 1, 2014
As of December 2022, New Jersey Medicaid managed care enrollment was up 7 percent to nearly 2.2 million.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total New Jersey
2,100,947
2,113,930
2,125,181
2,130,868
2,144,514
2,158,966
+/- m/m
10,897
12,983
11,251
5,687
13,646
14,452
% y/y
7.4%
7.4%
7.2%
7.0%
7.1%
7.0%
New Mexico
Medicaid Expansion Status: Expanded January 1, 2014
As of December 2022, New Mexico’s Centennial Care program covered nearly 816,000 members, up 2.3 percent from the previous year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total New Mexico
809,991
811,732
812,995
813,630
814,466
815,798
+/- m/m
2,491
1,741
1,263
635
836
1,332
% y/y
4.2%
3.7%
3.4%
3.0%
2.6%
2.3%
New York
Medicaid Expansion Status: Expanded January 1, 2014
New York’s Medicaid managed care programs collectively covered nearly 6 million beneficiaries as of December 2022, a 4.6 percent increase from the previous year. The Medicaid Advantage program ended in December 2021.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Mainstream MCOs
5,399,089
5,395,489
5,418,915
5,446,409
5,467,467
5,494,358
Managed LTC
255,999
256,538
258,236
257,360
260,087
264,965
Medicaid Advantage
0
0
0
0
0
0
Medicaid Advantage Plus
34,357
34,355
34,689
34,764
34,717
35,061
HARP
164,514
165,067
165,024
166,063
165,340
165,713
FIDA-IDD (Duals)
1,656
1,659
1,655
1,668
1,677
1,685
Total New York
5,855,615
5,853,108
5,878,519
5,906,264
5,929,288
5,961,782
+/- m/m
39,970
(2,507)
25,411
27,745
23,024
32,494
% y/y
4.5%
4.3%
4.2%
4.3%
4.5%
4.6%
North Carolina
Medicaid Expansion Status: Not Expanded
As of December 2022, enrollment in North Carolina’s Medicaid managed care program was 1.8 million, up 9.5 percent from the prior year. North Carolina implemented Medicaid managed care on July 1, 2021.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total North Carolina
1,738,545
1,746,948
1,757,503
1,768,974
1,778,199
1,837,423
+/- m/m
9,047
8,403
10,555
11,471
9,225
59,224
% y/y
8.0%
6.8%
6.7%
6.6%
6.6%
9.5%
Ohio
Medicaid Expansion Status: Expanded January 1, 2014
As of December 2022, enrollment across all four Ohio Medicaid managed care programs was nearly 3 million, up 0.9 percent from the prior year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
CFC Program
1,800,781
1,800,038
1,798,135
1,796,327
1,798,873
1,804,860
ABD/Duals
348,071
348,176
347,461
347,371
347,473
347,839
Group 8 (Expansion)
815,879
815,402
815,326
814,968
815,637
821,064
Total Ohio
2,964,731
2,963,616
2,960,922
2,958,666
2,961,983
2,973,763
+/- m/m
(1,340)
(1,115)
(2,694)
(2,256)
3,317
11,780
% y/y
3.4%
2.6%
1.9%
1.4%
1.0%
0.9%
Oregon
Medicaid Expansion Status: Expanded January 1, 2014
As of December 2022, enrollment in the Oregon Coordinated Care Organization (CCO) Medicaid managed care program was more than 1.2 million, up 7.2 percent from the previous year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total Oregon
1,193,358
1,202,198
1,206,520
1,211,099
1,221,435
1,228,054
+/- m/m
3,920
8,840
4,322
4,579
10,336
6,619
% y/y
8.3%
8.4%
7.7%
7.6%
7.4%
7.2%
Pennsylvania
Medicaid Expansion Status: Expanded January 1, 2015
As of December 2022, Pennsylvania’s Medicaid managed care enrollment was nearly 3 million, up 6.5 percent in the past year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total Pennsylvania
2,895,837
2,909,985
2,920,584
2,937,049
2,950,613
2,966,207
+/- m/m
13,973
14,148
10,599
16,465
13,564
15,594
% y/y
7.4%
7.3%
6.9%
6.8%
6.6%
6.5%
South Carolina
Medicaid Expansion Status: Not Expanded
South Carolina’s Medicaid managed care programs collectively enrolled nearly 1.1 million members as of December 2022, which represents an increase of 7.5 percent in the past year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total Medicaid
1,041,909
1,049,706
1,056,026
1,064,548
1,071,016
1,076,146
Total Duals Demo
13,876
13,739
13,543
13,546
13,513
13,431
Total South Carolina
1,055,785
1,063,445
1,069,569
1,078,094
1,084,529
1,089,577
+/- m/m
5,226
7,660
6,124
8,525
6,435
5,048
% y/y
7.6%
7.5%
7.4%
7.9%
7.6%
7.5%
Tennessee
Medicaid Expansion Status: Not Expanded
As of December 2022, TennCare managed care enrollment totaled 1.7 million, up 5.8 percent from the prior year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total Tennessee
1,692,395
1,704,398
1,710,125
1,718,539
1,726,603
1,734,108
+/- m/m
6,737
12,003
5,727
8,414
8,064
7,505
% y/y
6.0%
6.1%
6.1%
6.0%
5.9%
5.8%
Texas
Medicaid Expansion Status: Not Expanded
Texas’ state fiscal year begins in September and program-specific enrollment is only reported at the end of each state fiscal quarter. As of November 2022, Texas Medicaid managed care enrollment was nearly 5.7 million across the state’s six managed care programs, up 10.6 percent from the previous year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
STAR
4,559,293
4,748,820
STAR+PLUS
559,746
568,456
STAR HEALTH
45,760
46,228
Duals Demo
34,336
33,673
CHIP
97,153
85,773
STAR KIDS
169,757
170,219
Total Texas
5,466,045
5,653,169
+/- m/m
% y/y
8.6%
10.6%
Virginia
Medicaid Expansion Status: January 1, 2019
Virginia Medicaid managed care enrollment was up 9.8 percent in December 2022 to 1.6 million members.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total Virginia
1,572,923
1,582,973
1,589,722
1,598,875
1,608,840
1,619,311
+/- m/m
11,829
10,050
6,749
9,153
9,965
10,471
% y/y
11.3%
11.0%
10.0%
9.6%
10.1%
9.8%
Washington
Medicaid Expansion Status: Expanded January 1, 2014
Washington’s Medicaid managed care enrollment increased 7.2 percent to nearly 2 million as of December 2022, compared to the previous year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total Washington
1,884,734
1,898,983
1,904,127
1,913,230
1,927,690
1,959,278
+/- m/m
8,867
14,249
5,144
9,103
14,460
31,588
% y/y
#DIV/0!
#DIV/0!
5.8%
5.9%
6.0%
7.2%
West Virginia
Medicaid Expansion Status: Expanded January 1, 2014
As of December 2022, West Virginia’s Medicaid managed care program covered 533,000 members, up 5.7 percent year-over-year.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
Total West Virginia
519,992
524,042
524,922
527,226
530,494
533,194
+/- m/m
2,871
4,050
880
2,304
3,268
2,700
% y/y
6.5%
6.8%
6.4%
5.9%
5.9%
5.7%
Wisconsin
Medicaid Expansion Status: Not Expanded
Across Wisconsin’s three Medicaid managed care programs, December 2022 enrollment totaled nearly 1.2 million, up 6.6 percent from the year before.
Jul-22
Aug-22
Sep-22
Oct-22
Nov-22
Dec-22
BadgerCare+
1,042,456
1,047,217
1,053,361
1,059,587
1,065,182
1,070,788
SSI
61,841
61,916
62,065
62,129
62,165
62,293
LTC
56,905
57,075
57,293
57,488
57,552
57,592
Total Wisconsin
1,161,202
1,166,208
1,172,719
1,179,204
1,184,899
1,190,673
+/- m/m
5,263
5,006
6,511
6,485
5,695
5,774
% y/y
7.5%
7.2%
7.1%
7.1%
6.9%
6.6%
More Information Available from HMA Information Services
More detailed information on the Medicaid managed care landscape is available from HMA Information Services (HMAIS), which collects Medicaid enrollment data, health plan financials, and the latest on expansions, waivers, duals, ABD populations, long-term care, accountable care organizations, and patient-centered medical homes. HMAIS also includes a public documents library with copies of Medicaid RFPs, responses, model contracts, and scoring sheets.
HMAIS enhances this publicly available information with an overview of the structure of Medicaid in each state, as well as proprietary Medicaid Managed Care RFP calendars.
For additional information on how to subscribe to HMA Information Services, contact Carl Mercurio at 212-575-5929 or cmercurio@healthmanagaement.com.
[1] Arizona, California, District of Columbia, Florida, Georgia, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maryland, Michigan, Minnesota, Mississippi, Missouri, Nebraska, Nevada, New Jersey, New Mexico, New York, North Carolina, Ohio, Oregon, Pennsylvania, South Carolina, Tennessee, Texas, Virginia, Washington, West Virginia, Wisconsin.
This week, our In Focus section highlights a Wakely, an HMA Company, summary and analysis of the 2024 Medicare Advantage Advance Notice, prepared for America’s Health Insurance Plans (AHIP). The Centers for Medicare & Medicaid Services (CMS) released the contract year (CY) 2024 Advance Notice with an accompanying fact sheet on February 1, 2023. AHIP has retained Wakely Consulting Group to provide a financial impact summary report of the information presented in the notice. Specifically, Wakely was asked to analyze changes to Medicare Advantage (MA) revenue, risk adjustment models, and fee-for-service (FFS) normalization.
Key highlights of the analysis are:
The CY 2024 FFS growth rate is lower than projections from the 2023 Final Announcement. A portion of the downward restatement is driven by a technical change. CMS has not commented on the additional drivers.
Based on a large sample of plans, Wakely estimated that the proposed Part C risk adjustment model is expected to decrease plan risk adjusted payment by 3.7 percent overall, which represents a bigger headwind than the CMS estimated decrease of 3.12 percent. The impacts vary significantly by model segment and geographic region, and for individual plans.
The proposed FFS normalization factor excludes PY 2021 risk scores in the calculation of the underlying trend. The exclusion of PY 2021 increases the FFS normalization factor which decreases PY 2024 risk scores.
The report, released March 6, 2023, provides additional detail and discussion of these issues. For questions, please contact Tim Courtney or Rachel Stewart.
This week, our In Focus reviews a new Health Management Associates (HMA) report, highlighting hybrid (in-person & virtual visits) as the future of child welfare service delivery. During the COVID-19 public health emergency (PHE), the federal government waived the requirement for “once every 30 days” in-person visits by caseworkers for children in foster care, allowing these visits to occur virtually. In 2021, Casey Family Programs (CFP) commissioned HMA to evaluate the delivery of virtual child welfare services and outline the implications of the COVID-19 PHE on the child welfare system.
The report “Evaluating the Delivery of Virtual Child Welfare Services” is now available. It summarizes HMA’s findings and elevates the voices of staff in public and private child welfare agencies, and of youth and families with lived experiences, and examines their perspectives on how well virtual services have worked. It also details the implications of the COVID-19 PHE, the response from public child welfare agencies, and offers guidance on a hybrid (part in-person, part virtual) service model, which we believe will continue to be a factor in the future delivery of child welfare services.
As the COVID-19 PHE accelerated the spread and scale of telehealth adoption in health care, we surmised that the experience offered valuable opportunities to learn more about how the health care sector’s adoption of telehealth services could be applied in the child welfare community. While cognizant of the unique considerations for child welfare, this disruption also represents a substantial opportunity to rethink the child welfare system and advance both the use of technology as well as a more prevention- and strengths-based approach to child welfare.
The report highlights innovative approaches in the field, offers questions to frame a jurisdiction’s decision-making process, and provides a tool to facilitate an informed decision on the hybrid model. The report also offers a broader value proposition that outlines policy, practice, workforce, and technology imperatives to develop a hybrid approach to the delivery of child welfare services.
This week our In Focus section reviews the Centers for Medicare and Medicaid Services’ (CMS) announcement that the agency will explore three new prescription drug payment models in the Medicare and Medicaid programs:
Medicare High-Value Drug List Model
Cell and Gene Therapy (CGT) Access Model
Accelerating Clinical Evidence Model
The announcement – and accompanying report – responds to President Biden’s October 2022 Executive Order directing CMS’ Center for Medicare and Medicaid Innovation (the Innovation Center) to identify models that could lower cost sharing for commonly used drugs and include value-based payment for drugs.
Notably, the Innovation Center offered varying levels of specificity about the models, leaving unanswered many questions about the structures and timelines for the potential models. The Innovation Center will need to conduct more robust analysis to determine the design specifications for each model, stakeholder interest, and practical and political feasibility for each. In addition, each model will need to have its own application or rulemaking process to identify participants and other key model parameters. While this makes it difficult for the Innovation Center to specify timelines, it provides stakeholders some flexibility to analyze and develop recommendations for the potential models over the next several months.
HMA’s experts are also closely tracking CMS’ work on additional areas identified for the agency to research. For example, CMS could consider other regulatory pathways, partnerships, or campaigns to promote the following changes:
Opportunities to encourage price transparency for prescription drugs
Options to improve biosimilar adoption
Medicare fee-for-service options to support CGT access and affordability
The drug payment models build on other federal and state-level efforts to address prescription drug costs and total cost of care initiatives. For example, CMS’ drug payment model announcement comes just a week after the agency released its implementation approach for the drug payment policies approved as part of the inflation Reduction Act of 2022 (IRA) (P.L. 117-169). CMS is balancing the extensive implementation needs for the IRA while also acknowledging the new law may not directly address other value-based considerations impacting cost and access for certain prescription medications.
Below are some of the highlights of the Innovation Center’s drug payment models.
Medicare High Value Drug List Model
The Medicare High Value Drug List model would provide standardized approach to cost sharing for specified Part D medications. CMS suggests a standardized list with consistent cost-sharing to allow providers to easily identify and prescribe appropriate medications. Part D Sponsors could offer a Medicare-defined standard set of approximately 150 high-value generic drugs with a maximum co-payment of $2 for a month’s supply. Under this model, generic drugs included in the standardized list would not be subject to step therapy, prior authorization, quantity limits, or pharmacy network restrictions.
According to the report, CMS could explore leveraging existing systems, which would allow for a streamlined implementation. CMS also plans to seek input from beneficiaries, Part D Sponsors, manufacturers, and providers, but the agency did not provide a more specific timeline for announcing the Model specifications and start date.
Cell and Gene Therapy (CGT) Access
The Cell and Gene Therapy (CGT) Access model would be a voluntary opportunity for states and manufacturers. The model builds on existing state Medicaid initiatives to develop outcomes-based agreements (OBAs) with certain manufacturers of high-cost and breakthrough medications. CMS suggests the multistate test could inform a more permanent framework for evaluating, financing, and delivering CGTs on a broader scale. This model may also help address complexities with the federal drug rebate requirements in states that wish to pursue value-based contracting arrangements. Under this model a state Medicaid agency could choose to adopt the CMS structure for multi-state OBAs with participating manufacturers. CMS would be responsible for implementing, monitoring, reconciling, and evaluating financial and clinical outcomes. Initially the model would focus on CGTs for illnesses like sickle cell disease and cancer. This approach could remove some of the barriers that have slowed state uptake of OBAs.
CMS plans to begin model development in 2023, announce the model sometime in 2024-25, and test it as early as 2026.
Accelerating Clinical Evidence Model
The Innovation Center is considering mandatory participation for Medicare Part B providers in the Accelerating Clinical Evidence Model. Under this potential model, the agency would adjust Medicare Part B payment amounts for Accelerated Approval Program (AAP) drugs to determine if adjustments incentivize manufacturers to timely complete trials, which in turn may facilitate earlier availability of clinical evidence.
The Innovation Center identified some challenging aspects for this model and stated the agency will need to consult with the U.S. Food and Drug Administration (FDA) in 2023 to consider approaches for this model. Statements from agency officials about the model also indicate the need for consultation with the Medicare Payment Advisory Commission (MedPAC) and other stakeholders, including through an Advance Notice of Proposed Rulemaking.
If the Innovation Center determines this model is feasible, the agency will provide more details about a targeted launch. The Innovation Center has previously attempted to implement mandatory Part B drug payment models but never implemented them due to legal challenges and stakeholder opposition.
HMA and HMA companies will continue to analyze these potential models and initiatives developing in parallel with the Innovation Center’s work. We have the depth and breadth of expertise to assist with tailored analysis, to model policy impacts of the potential models, and to support the drafting of feedback to CMS as it considers these options.
This week our In Focus section reviews President Joseph R. Biden’s 2023 State of the Union Address (SOTU) to Congress. The President highlighted specific actions that Congress, and the Administration have taken over the last two years to advance his health care priorities.
During his first SOTU address in 2022, President Biden announced the creation of a “Unity Agenda”, which included priority policy areas with potential for bi-partisan support. The President highlighted several steps the Administration has taken to advance the “Unity Agenda” including:
The bipartisan effort to enact the Mainstreaming Addiction Treatment (MAT) Act, which removed the federal requirement for practitioners to have a waiver (known as the X-waiver) to prescribe medications, like buprenorphine, for the treatment of opioid use disorder
The Cancer Moonshot announcements for almost 30 new programs, policies, and resources to close the screening gap, tackle environmental exposure, decrease preventable cancers, advance cutting-edge research, support patients and caregivers, and more.
Addressing mental health needs through the expansion of Certified Community Behavioral Health Clinics and launch of the 988-suicide prevention hotline.
In his SOTU and accompanying White House materials, the President also proposed new policies and initiatives to further advance his health care agenda. These actions include a combination of issues that would require Congressional approval as well as actions regulatory agencies can already advance. Congress and the Administration are expected to build on previous bipartisan achievements to tackle the nation’s dual crises with addiction and mental health.
Notably, the policies outlined in the SOTU foreshadow an active regulatory agenda over the next 18 months as the Administration seeks to solidify key aspects of the President’s health care agenda ahead of the next Presidential election.
The Administration’s planned actions include the following:
Opioids
Calling on Congress to pass legislation to permanently schedule all illicitly produced fentanyl-related substances into Schedule I.
SAMHSA will provide enhanced technical assistance to states who have existing State Opioid Response funds, and will host peer learning forums, national policy academies, and convenings with organizations distributing naloxone beginning this spring.
By this summer, the Federal Bureau of Prisons will ensure that each of their 122 facilities are equipped and trained to provide in-house medication-assisted treatment (MAT).
This spring CMS will provide guidance to states on the use of federal Medicaid funding to provide health care services—including treatment for people with substance use disorder—to individuals in state and local jails and prisons prior to their release. California is the first state to receive approval for a similar initiative.
Mental Health
CDC plans to launch a new campaign to provide a hub of mental health and resiliency resources to health care organizations in better supporting their workforce.
The Department of Education (ED) will announce more than $280 million in grants to increase the number of mental health care professionals in high-need districts and strengthen the school-based mental health profession pipeline.
HHS and ED will issue guidance and propose a rule to make it easier for schools to provide health care to students and more easily bill Medicaid for these services.
The Administration is scheduled to propose new mental health parity rules this spring.
HHS will improve the capacity of the 988 Lifeline by investing in an expansion of the crisis care workforce; scaling mobile crisis intervention services; and developing additional guidance on best practices in crisis response.
HHS also plans to promote interstate license reciprocity for delivery of mental health services across state lines.
HHS intends to increase funding to recruit future mental health professionals from Historically Black Colleges and Universities and to expand the Minority Fellowship Program.
The Department of Veterans Affairs (VA), working with HHS and Defense, will launch a program for states, territories, Tribes and Tribal organizations to develop and implement proposals to reduce suicides in the military and among veterans.
VA will also increase the number of peer specialists working across VA medical centers to meet mental health needs
Cancer Moonshot
The President called on Congress to reauthorize the National Cancer Act to overhaul cancer research and to extend the funding for biomedical research established in the 21st Century Cures Act.
The Administration will take steps to ensure that patient navigation services are covered by insurance. This could require legislation depending on which type on insurance an individual has.
Health care costs
Urging Congress to pass legislation to cap insulin prices in all health care markets. Expanding the $35 insulin cap to commercial markets will require the 60 votes in the Senate.
Home and community services
Working with Congress to approve legislation to ensure seniors and people with disabilities can access home care services and to provide support to caregivers.
HMA and HMA companies are closely monitoring these federal policy developments. We can assist healthcare stakeholders in responding to the immediate opportunities and challenges that arise and contextualize these actions for longer-term strategic business and operational decisions.
What are your plans to minimize your risk to avoid dropping in your Star Rating or to plan a head to maintain or improve your Star Rating?
On February 1, 2023, the Center for Medicare and Medicaid Services (CMS) released the 2024 Advance Notice and included some key specifics on the upcoming changes to the Medicare Star Rating program. CMS is proposing changes that will align with the recently announced “Universal Foundation” of quality measures, a core set of measures that are aligned across CMS quality rating and value-based care programs. The Advance Notice also included information on substantive measure specification updates, new measure concepts, and the addition of measures to align with other CMS programs.
Moderators of this session are HMA’s Mary Walter, Managing Director of Quality and Accreditation, and David Wedemeyer, Principal. Both have health plan legacy experience in Stars strategy, execution and getting results.
Objectives of this session:
Overview of the CMS proposed changes and their impact on the Stars program
Attendees will obtain a blueprint for improving Medicare Advantage Star Ratings, including the importance of ensuring executive management buy-in
Discussion of how the use of data analytics can help plans to identify quality gaps, target interventions, and track improvement
Strategies to avoid the type of siloed initiatives that often fail to achieve lasting results
Speakers will also address the importance of quality in achieving market viability and financial sustainability
Stay in the know about the upcoming proposed changes and develop your organization’s strategy in this interactive impactful working session. This session will allow attendees to integrate any learnings and take-aways into your Stars program to meet your overall Star Rating strategic goal.
Follow #HMAtalksQuality on Twitter and LinkedIn for more updates on Stars and quality initiative efforts throughout the year. View the full agenda and register for HMA’s first annual quality conference on March 6 in Chicago. Registration closes on February 21, 2023.
At HMA, our subject matter experts get questions every day from people working in state agencies, counties, health plans and provider groups about how to “right size” the behavioral health continuum to obtain equitable access for growing behavioral health demand. From legislatures to providers, improving access to mental health services is critical to improving overall health outcomes. It is time for behavioral health to create a specific definition of network adequacy that accounts for the complexity and nuance of access to mental health and substance use care. It is time to identify and define the factors that lead to “adequate” provider capacity, to ensure that the right level of care is available to individuals when they need care. Network adequacy in behavioral health needs an overhaul to meet the complexity that is driving access challenges.
Together let’s re-define what “adequate” means in behavioral health to ensure we build systems that meet the needs of communities. At HMA’s quality conference on March 6 in Chicago, the “Developing a Behavioral Health Quality Strategy” working session will engage participants in an in-depth discussion on identifying factors to inform a more accurate definition of behavioral health network adequacy. Speakers will outline some of the core challenges in network adequacy and innovations they have used. Attendees will work collaboratively in a structured exercise on three knotty challenges within network adequacy to identify factors that could improve measurement for states, plans and providers. The goal is for participants to walk away with tangible actions they can implement in their work on behavioral health access.
And follow #HMAtalksQuality on Twitter and LinkedIn for more updates on behavioral health quality efforts throughout the year. View the full agenda and register for HMA’s first annual quality conference on March 6 in Chicago. Registration closes on February 21, 2023.
Leaders at the Centers for Medicare and Medicaid Services (CMS) announced in the New England Journal of Medicine this month a new initiative called the “Universal Foundation,” which seeks to align quality measures across the more than 20 CMS quality initiatives. The implications for the broader healthcare system are immense.
At Health Management Associates upcoming quality conference March 6 in Chicago, Dr. Lee Fleisher, one of the authors of the Universal Foundation initiative and, Chief Medical Officer and Director, CMS’ Center for Clinical Standards and Quality, will deliver the keynote address “A Vision for Healthcare Quality: How Policy Can Drive Improved Outcomes.”
Attendees will hear from industry leaders and policy makers about evolving healthcare quality initiatives and participate in substantive workshops where they will learn about and discuss solutions that are using quality frameworks to create a more equitable health system. In addition to Dr. Fleisher, featured speakers will include executives from American College of Surgeons, ANCOR, CareJourney, CareOregon, Commonwealth Care Alliance, Council on Quality and Leadership, Denver Health, Institute on Public Policy for People with Disabilities, Intermountain Health, NCQA, Reema Health, Kaiser Permanente, Social Interventions Research and Evaluation Network, UnitedHealth Group, United Hospital Fund, 3M, and many other organizations.
The Universal Foundation seeks to align quality measures to “focus providers’ attention on measures that are meaningful for the health of broad segments of the population; reduce provider burden by streamlining and aligning measures; advance equity with the use of measures that will help CMS recognize and track disparities in care among and within populations; aid the transition from manual reporting of quality measures to seamless, automatic digital reporting; and permit comparisons among various quality and value-based care programs, to help the agency better understand what drives quality improvement and what does not.”
CMS has established a cross-center working group focused on coordination of these processes and on development and implementation of aligned measures to support a consistent approach. As part of this announcement, the group published a list of Preliminary Adult and Pediatric Universal Foundation Measures. This new quality program will affect clinicians, healthcare settings such as hospitals or skilled nursing facilities, health insurers, and value-based entities such as accountable care organizations.
HMA can help organizations improve their quality efforts in line with the new CMS Universal Foundation initiative. HMA’s more than 500 consultants include past roles as senior officials in Medicaid and Medicare, directors of large nonprofit and social services organizations, top-level advisors, C-level executives at hospitals, health systems and health plans, and senior-level physicians. Our depth of industry-leading policy expertise and clinical experience provides comprehensive solutions that make healthcare and human services work better for people.
To learn more about HMA and Quality, follow #HMAtalksQuality on Twitter and LinkedIn. View the full agenda and register for HMA’s first annual quality conference on March 6 in Chicago. Registration closes on February 21, 2023.
This week, our In Focus section reviews recently announced major policy updates from the Centers for Medicare & Medicaid Services (CMS) that affect the Medicare Advantage (MA) and Part D programs. First, on January 30, CMS released the final Risk Adjustment Data Validation Final Rule, a highly anticipated and controversial policy that establishes the agency’s approach to auditing MA Organizations’ (MAOs) risk-adjustment payments and collecting overpayments as needed.
Then, on February 1, CMS published the Calendar Year (CY) 2024 Advance Notice for the MA (Part C) and Part D Prescription Drug Programs. Between these two directives and the proposed MA policy changes CMS announced in December 2022, the Administration continues its efforts to actively manage Medicare Advantage and strengthen quality and oversight of the program. HMA’s summary of the December 2022 proposed rule is available here.
Below are some highlights of the 2024 Advance Notice. By law, CMS must notify the public of planned changes in the MA capitation rate methodology and risk adjustment methodology annually. The deadline for submitting comments to CMS is Friday, March 3, 2023.
Payment Impact in MA: CMS is projecting an average increase in revenue of 1.09 percent in plan payments from last year. This percentage increase is based on a net number that reflects multiple factors including growth rates, change in STAR ratings, and risk score trends.
Risk Adjustment: CMS is seeking to make some refinements to the Part C risk-adjustment model. For example, CMS will begin using the International Classification of Diseases (ICD)-10 classification system (instead of the ICD-9 classification system) and updated underlying fee for service data years. More specifically, diagnoses data years are being updated from 2014 to 2018, and expenditure years are being updated from 2015 to 2019 to reflect changes in costs.
Star Ratings: CMS is proposing updates and refinements to the Star Ratings program, including:
Retiring the diabetes care-kidney disease monitoring and Medication Reconciliation Post-Discharge
Expanding the age range for colorectal cancer screening measure to 45−75 years old to align with the preventive task force
Adding the Care for Older Adults (COA)—Functional Status Assessment measure back to the Star Ratings, and introducing Kidney Health Evaluation for Patients with Diabetes (KED), Concurrent Use of Opioids and Benzodiazepines (COB), Polypharmacy Use of Multiple Anticholinergic Medications in Older Adults (Poly-ACH), and polypharmacy Use of Multiple Central Nervous System Active Medications in Older Adults (Poly-CNS)
Introducing a case-mix adjustment to Part D medication adherence measures for diabetes, hypertension, and cholesterol.
CMS also is seeking to potentially align measures with other CMS programs. Specifically, the agency is introducing a “Universal Foundation” of quality measures, which is a core set of metrics aligned across programs. Additional information can be found in this New England Journal of Medicine “Perspective”.
Part D Impact
The Advance Notice also notifies plans on the changes to the Part D benefit occurring in 2024 as a result of the Inflation Reduction Act (IRA), including:
Beginning in CY 2024, CMS will eliminate cost-sharing for Part D drugs prescribed to beneficiaries in the catastrophic phase of coverage.
Beginning in CY 2024, the Low-Income Subsidy program (LIS) under Part D will be expanded so that beneficiaries who earn 135−150 percent of the federal poverty level and meet statutory resource limit requirements will receive the full LIS subsidies that were available only to beneficiaries earning less than 135 percent of the federal poverty level prior to 2024.
During CY 2024, CMS will prohibit Part D plans from applying the deductible to any Part D covered insulin product and from charging more than $35 for each month’s supply of a covered insulin product in the initial coverage phase and the coverage gap phase.
During CY 2024, CMS will prohibit Part D plans from applying the deductible to an adult vaccine recommended by the Advisory Committee on Immunization Practices and from charging any cost-sharing payments at any point in the benefit for these vaccinations.
Beginning in CY 2024, CMS will cap the growth in the Base Beneficiary Premium at 6 percent. The Base Beneficiary Premium for Part D is limited to the lesser of a 6 percent annual increase or the amount that would otherwise apply under the prior methodology had the IRA not been enacted.
The HMA Medicare team will continue to analyze these proposed changes. We have the depth and breadth of expertise to assist with tailored analysis, to model policy impacts across the multiple rules, and to support the drafting of comment letters on this notice.
If you have questions about the contents of CMS’s MA advance notice and how it will affect MA plans, providers, and patients, contact Julie Faulhaber (jfaulhaber@healthmanagement.com), Amy Bassano (abassano@healthmanagement.com), or Andrea Maresca (amaresca@healthmanagement.com).
