Medicare Compliance & Reimbursement

Deadline: Submit your comments on the advance notice before March 3.

CMS expects a significantly lower Medicare Advantage (MA) and Part D payment rate increase for 2024. If you want to offer your opinion on the changes, you’ll need to get on it ASAP.

Context: On Feb. 1, the Centers for Medicare & Medicaid Services (CMS) released the calendar year (CY) 2024 Advance Notice of Methodological Changes for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies. The notice reviews CMS’ payment rate methodology and alignment with Inflation Reduction Act provisions.

CMS estimates a 2.09 percent increase to MA plans’ revenue for 2024, according to the fact sheet on the notice. Last year’s final rate announcement for the effective growth rate ended up at 4.88 percent.

“Accounting for the impact of the benchmark rate cap, MA rebate and other policies, the net impact on the Medicare Trust Funds for CY 2024 is expected to be $7.3 billion,” clarify attorneys Ankur J. Goel and Emily R. Curran with law firm McDermott Will & Emery in online legal analysis. “CMS estimates the expected average change in revenue for MA organizations (MAOs) to increase by 1.03 percent in CY 2024, down from an 8.50 percent increase in CY 2023,” Goel and Curran add.

Factor in These 2 Key Points

The notice looks at CMS’ proposed technical revisions under the Part C risk adjustment model. CMS proposes “restructur[ing] condition categories using the International Classification of Diseases (ICD)-10 classification system (instead of the ICD-9 classification system), and updat[ing] underlying FFS data years (from 2014 diagnoses and 2015 expenditures to 2018 diagnoses and 2019 expenditures), as well as revisions focus[ing] on conditions that are subject to more coding variation,” the fact sheet says.

Under the advance notice, CMS looks at updating future measures and adding a “Universal Foundation” of core measures in the MA Star Ratings program. “CMS is also soliciting initial feedback on potential substantive measure specification updates, new measure concepts, and the addition of measures to align with other CMS programs,” the fact sheet explains.

Interested parties must offer CMS their opinions by March 3 as the agency plans on making a final MA and Part D rate announcement for CY 2024 by April 3. You must reference docket number “CMS- 2023-0010” in the “search” field at www.regulations.gov and follow the directions.

Resource Read the advance notice at www.cms.gov/files/ document/2024-advance-notice.pdf.