Premier Comments on Medicare Parts C and D Proposed Rule

Premier submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed Medicare Advantage (MA) and Medicare Prescription Drug Benefit (Part D) programs for contract year 2024. The proposed rule seeks public comment on CMS’ proposals to ensure timely access to care, protect beneficiaries from predatory marketing practices, strengthen quality through the Star Ratings Program, advance health equity, improve access to behavioral health services and improve drug affordability and access in Part D.

Premier expressed appreciation for CMS’ commitment to enabling access to high-quality, equitable care, as evidenced by the proposed policies in this rule. In detailed comments, Premier specifically recommends that CMS:

• Improve collection and reporting of social risk factor data alongside industry stakeholders to target social determinants of health more directly before proceeding with the proposed Health Equity Index reward;
• Limit significant year-over-year changes to the MA and Part D Star Ratings Program methodology to improve stability and incentivize multi-year quality improvement investments;
• Codify standards for coverage criteria to ensure that basic benefits coverage for MA enrollees is no more restrictive than under Medicare fee-for-service (FFS);
• Develop demonstration programs to provide MA plans with additional flexibilities and/or financial rewards for implementing real-time prior authorization programs with contracted providers;
• Finalize proposals that leverage network adequacy and other MA and Part D program requirements to improve access to behavioral health services, while limiting the use of flexibilities that may unintentionally encourage plans to use telehealth services as substitutes for existing in-person services;
• Finalize proposals that enhance beneficiary protections against predatory marketing practices;
• Finalize proposed changes to expand beneficiary access to medication therapy management (MTM) programs, while ensuring beneficiaries residing in long-term care (LTC) settings have access to MTM services; and
• Codify transitions of care protections for beneficiaries who experience a change in the level of care.