If you missed NCQA’s letter to Seema Verma, CMS Administrator, about proposed changes to Medicare Advantage and other programs for 2019, here’s a quick summary.
Opioid Limits. We strongly support the proposal to let plans limit opioids to certain prescribers and pharmacies for patients at risk of addiction. This policy is urgently needed to help address the opioid epidemic sweeping our nation. It also parallels NCQA’s new HEDIS opioid measures.
Value-Based Insurance Design. We support allowing plans to reduce cost sharing, tailor supplemental benefits and vary deductibles for patients who meet specific medical criteria. Private employers such as Pitney Bowe have achieved significant savings from reduced cost sharing for essential diabetes treatments.
Medical Loss Ratio. We support the addition of anti-fraud efforts and Medical Therapy Management (MTM) program costs to spending for the medical loss ratio.
Improving Measures. We urge CMS to develop measures and systems to reward plans for reducing racial, ethnic and other socioeconomic disparities in care.
Geographic/Market Area Characteristics. We are skeptical about the potential change to Star Ratings for geographic factors, such as in areas that are rural or dominated by provider monopolies.
New Entrants. To level the field on quality between new and experienced Medicare Advantage plans, CMS could temporarily enhance the scores of new entrants with current NCQA Accreditation.
Default Enrollments. We urge CMS to require NCQA Accreditation when allowing passive enrollment into Medicaid plans after nonrenewal of a plan that served dual-eligible (Medicare and Medicaid) beneficiaries.
Patient Experience, Complaints & Access Measures. The Consumer Assessment of Health Plans Survey is long, has low responses and long lags in feedback. Complaint measures also merely assess raw numbers and do not yet differentiate between low-level issues, multiple calls from the same enrollee and other important distinctions. Once we have better measures in these areas, it would make sense to consider increasing the weights.
You can read the entire letter, including additional recommendations for consideration, here.
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