CMS is seeking comments on its proposed updates to the methodologies used to pay Medicare Advantage (MA) and Part D plan sponsors for 2019. This year CMS released its 2019 Advance Notice and Draft Call Letter in two parts. In late 2017, CMS released proposed changes to the Part C risk adjustment model (Part I of the Advance Notice) to comply with new 21st Century Cures Act requirements. Part II of the Advance Notice and Call Letter, released earlier this month, includes proposed rate updates and various policy provisions. According to a CMS fact sheet, the update would increase plan payments by 1.84% relative to 2018, without taking into account an adjustment for underlying coding trend, which CMS expects to increase risk scores by 3.1% on average.

In the Draft Call Letter, CMS proposes to reinterpret the “primarily health related” supplemental benefit standard to allow MA plans to offer a broader range of benefits, including “daily maintenance” items (e.g., fall prevention devices). Under the new interpretation, CMS proposes that a service or item that is primarily health related “must diagnose, prevent, or treat an illness or injury, compensate for physical impairments, act to ameliorate the functional/psychological impact of injuries or health conditions, or reduce avoidable emergency and healthcare utilization.” CMS also proposes new strategies to address overutilization of opioids in the Part D program and new Star Ratings measures and measure specifications, among many other policy updates. Additionally, CMS solicits comments on certain aspects of mail-order auto-ship programs and potential modifications to current consent policies.

CMS will accept comments on both Part I and Part II of the Advance Notice and Draft Call Letter through March 5, 2018, and the agency anticipates releasing its final policies on April 2, 2018.