Comments: Medicare Advantage and Part D Proposed Rule

On March 7, 2022, LTQA submitted comments on the Medicare Program; Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs proposed rule.

LTQA appreciates CMS’ efforts to support MA beneficiaries with serious, chronic conditions and functional needs through this Proposed Rule. In our comments, we highlight several considerations on the provisions with potential impacts on non-medical supplemental benefits:

  • Requiring standardized questions on Social Determinants of Health (SDoH) will provide Special Needs Plans (SNPs) with actionable information on SDoH but they will lack authority to address the issues that are identified. LTQA encourages CMS to provide additional flexibilities to equip plans with the ability to address the social needs for which standardized data collection is being proposed in this rule.
  • We caution CMS that the Maximum Out-of-Pocket (MOOP) limit changes will most certainly lead to a reduction in the supplemental benefits offered to MA beneficiaries, and dually eligible beneficiaries in particular.
  • The proposed changes around coordinating MA supplemental benefits with Medicaid benefits are very complex to operationalize given the current limitations in data-sharing, the dynamic nature of supplemental benefit structure and eligibility determination, and potential disruption of beneficiaries’ regular services. LTQA encourages CMS to address these operational challenges and provide some discretion to plans to promote a person-centered approach to these benefits and ensure members can get the full range of benefits to which they are entitled.
  • We recommend that CMS consider adding to the proposed standardized disclaimer additional language around how supplemental benefits may not be available in every plan to every member in the plan to address beneficiary confusion.
  • Medical loss ratio reporting on supplemental benefits will provide greater transparency into spending and utilization for non-medical supplemental benefits. We urge CMS to align reporting requirements for SSBCI with those for primarily health-related benefits. We support the collection of clear, timely information at the most granular level that still respects plans’ privacy.


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