Premier Comments on Contract Year 2027 Medicare Advantage and Part D Proposed Rule

Premier submitted comments on the Medicare Advantage (MA) Program, Medicare Prescription Drug Benefit Program (Part D), and Medicare Cost Plan Program proposed rule for contract year 2027. In this rulemaking, CMS proposes to significantly streamline the measure set for the Part C and Part D Star Ratings programs, formally codify the Part D redesign provisions from the Inflation Reduction Act, create a new special enrollment period for beneficiaries whose providers have left their plan’s network and improve coordination of care for enrollees of Special Needs Plans.

In our comments, Premier recommends that CMS take a more surgical approach to deregulation in the MA and Part D programs than proposed, including:

• Preserving measures in the Star Ratings program that provide transparency around beneficiaries’ experiences with their Medicare plan, particularly if national average performance has decreased on the measure(s) within the past year;
• Maintaining the Diabetes Care—Eye Exam measure in the Part C Star Ratings to support the Administration’s ongoing efforts to combat the health effects of chronic disease, and to preserve the positive clinical improvements that the measure incentivizes;
• Retaining administrative measures in the Star Ratings program related to plans’ performance in the appeals process to maintain accountability as health plans operationalize their industry pledge to streamline prior authorization;
• Stratifying Part D Star Ratings measures by whether or not beneficiaries receive services from long-term care pharmacies in order to more closely monitor their quality of care;
• Finalizing proposed changes to help integrate and coordinate care for enrollees of Special Needs Plans;
• Completing rulemaking and any additional administrative requirements associated with cannabis rescheduling prior to allowing MA and Part D plans to expand coverage of these products;
• Maintaining robust medical loss ratio (MLR) reporting requirements as a tool to monitor for and prevent potential overpayment of MA plans associated with increased vertical integration;
• Focusing on strengthening network adequacy oversight of Part D prescription drug plans (PDPs) to ensure consistency in access for long-term care beneficiaries; and
• Acting as a convener and explore alternative reimbursement models for long-term care pharmacies with stand-alone and MA PDPs.