Comments: CY 2024 Medicare Advantage and Part D Proposed Rule

Publication Date: February 2023

On February 13, 2023, LTQA submitted comments on the Medicare Program; Contract Year 2024 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs proposed rule.

LTQA’s comments on this Proposed Rule draw from our extensive research on nonmedical supplemental benefits in Medicare Advantage—in partnership with ATI Advisory and supported by The SCAN Foundation—as well as our ongoing engagement with a working group comprised of national experts on MA and LTSS, which provides guidance on our research (known as the Leadership Circle).

Overall, LTQA applauds CMS’ efforts to promote health equity, improve beneficiary experience, and strengthen quality measurement through this proposed rule. We support the enhanced focus on disability status in CMS’ efforts to advance health equity in Medicare Advantage, as well as a shift towards a more holistic definition of “chronic condition” that accounts for the overall health and functional ability of an individual rather than focusing solely on a clinical diagnosis. The proposed changes also create new requirements and incentives for MA plans to address health equity, for which expanded primarily health-related benefits and SSBCI can be leveraged as powerful tools.


Supported by a grant from The SCAN Foundation – advancing a coordinated and easily navigated system of high-quality services for older adults that preserve dignity and independence. For more information, visit