Tuesday, Dec. 1, America's Health Insurance Plans (AHIP) submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) in response to its 2022 Medicare Advantage Advance Notice.

In the letter, AHIP commends CMS for acknowledging why nearly 25 million Americans have chosen Medicare Advantage (MA) plans--better care and better value through innovative, patient-centered programs that improve quality and reduce costs for seniors and others eligible for Medicare. AHIP also raises issues with the Advance Notice that could undermine the affordability, stability, and choices for consumers that MA plans deliver, including:

• Higher costs and implementation issues relating to Part D Rebate Rule
• Flawed ESRD payment methods that negatively impact all MA enrollees
• Lack of transparency on estimated COVID-19 vaccine costs and utilization changes
• Failure to address policies needed to hold plans and enrollees harmless under COVID-19

The letter links to a report prepared by Wakely Consulting Group LLC. which analyzes the financial impact of the Advance Notice as well as changes to the risk adjustment models and the impact of COVID-19 on CMS projections.

Please click here to view AHIP's comment letter.