Alliance + 45 Organizations Submit Comments on Needed Guardrails, Other Provisions of Medicare Advantage Rule
Published March 1, 2024
On March 1, the Alliance submitted comments on behalf of 46 organizations in response to the Fiscal Year 2025 Medicare Advantage (MA) Advance Notice. The annually-released regulation, issued by the Centers for Medicare and Medicaid Services (CMS), provides updated policies for MA insurance plans for the upcoming year.
The letter focused on the need for CMS to creative proactive guardrails to prevent harmful unintended consequences as a result of the shift in financial responsibility included in the Medicare Part D redesign in the Inflation Reduction Act. The law increases insurers’ liability for costs in the catastrophic phase of the Part D benefit from 15% last year to 60% in 2025. Due to this increased financial exposure and limited levers to shift costs, it is vital that CMS create clear guidelines and standards for the use of utilization management techniques, increased transparency and disclosure requirements, and dedicated education and outreach efforts. The letter also touches on high-level recommendations for relevant patient protections in the implementation of the Medicare Prescription Payment Plan (previously referred to as cost smoothing).