Medicare Advantage and Part D Advance Notice for CY 2022

CMS released the Part I of the 2022 Medicare Advantage and Part D Advance Notice to provide plans with earlier notification of proposed payment changes. This announcement is made three months earlier than the usual to provide Medicare Advantage organizations and Part D sponsors more time to take this information into consideration as they prepare their bids for 2022.

The main takeaway for you from this bundle of rulemaking is that the Medicare Advantage program is stronger than ever. Growth has remained strong despite reimbursement cuts to MA plans under the Affordable Care Act that brought their payment into parity with traditional Medicare.

COVID-19 Outbreak

The health and safety of America’s patients and provider workforce in the face of the COVID-19 public health emergency (PHE) is the top priority of the Trump Administration and CMS. CMS is working around the clock to equip the American healthcare system with maximum flexibility to respond to the COVID-19 PHE.

The CY 2022 Advance Notice is an example of how CMS is focused on implementing the policies that matter most for ensuring continuous and predictable payments across the health care system and ensure care can be provided where it is needed.

While the Advance Notice does not catalog CMS’ actions related to the COVID-19 outbreak, an overview of CMS’ actions related to the outbreak for MA organizations, PACE organizations, and Part D sponsors can be found at: CMS Flexibilities to fight COVID-19

CMS is removing the requirement for submission of 2020 Consumer Assessment of Healthcare Providers & Systems (CAHPS) survey data for Medicare health and drug plans for similar concerns about the potential associated with activities to collect and submit the survey data. Both Part C and D plans can use any CAHPS survey data collected for their internal quality improvement efforts.

This year’s Health Outcomes Survey, administered by NCQA in partnership with CMS as a component of HEDIS data collection, was scheduled to be from April through July 2020. This survey administration has been postponed to late summer, and CMS will continue to monitor the situation to see if any further adjustments are needed.

Medicare Advantage (Part C) and Part D Star Ratings

2022 Star Rating Calculations For 2022 Star Ratings, CMS expects Medicare Advantage contracts to submit HEDIS data in June 2021, and Medicare Advantage and Prescription Drug Plan (Part D) contracts to administer the CAHPS survey in 2021 as usual so there is not a concern about data collection for the 2020 performance period.

However, to address concerns about overall performance in 2020, we are changing the applicability date of the guardrails policy from January 1, 2020, to January 1, 2021, delaying implementation of the 5-percentage point cap so that cut points for the 2022 Star Ratings can change by more than 5 percentage points if national performance declines overall as a result of the outbreak.

CMS will calculate the Part C and D improvement measure scores for the 2022 Star Ratings as codified but recognizes that the COVID-19 outbreak may result in a decline in industry performance, therefore expanding the “hold harmless rule” to include all contracts at the overall and summary rating levels.

Part I of the Advance Notice Announcements and Documents

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