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CMS Issues Part II of 2022 Medicare Advantage and Part D Advance Notice

For CFOs, finance & reimbursement staff, government relations staff

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The Centers for Medicare & Medicaid Services (CMS) has issued Part II of the calendar year (CY) 2022 Advance Notice of Methodological Changes for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies. The proposed changes described in Advance Notice Parts I and II are expected to increase plan revenue by 2.82%. 

CMS is soliciting input on how to improve MA and Part D Star Ratings, specifically on a potential COVID-19 vaccination measure to encourage Medicare beneficiaries to receive the vaccine once available.  

For CY 2022, CMS proposes to apply a coding pattern adjustment of 5.9%, which is the minimum adjustment for coding pattern differences in diagnosis coding between MA organization and fee-for-service (FFS) providers required by the statute. For 2023 and beyond, CMS proposes to implement an updated version of the Part D risk adjustment model used to adjust direct subsidy payments for Part D benefits offered by stand-alone prescription drug plans and MA prescription drug plans.  

Consistent with the proposal for Part C in the Advance Notice Part I, CMS proposes relying entirely on encounter data and diagnoses from FFS claims to calculate risk scores for CY 2022. In addition, CMS proposes to discontinue its previous policy of supplementing diagnoses from encounter data with diagnoses from inpatient records submitted to the risk adjustment processing system for calculating beneficiary risk scores.  

CMS is also considering whether to propose revising the MA rate book to base it on data about beneficiaries with Part A and Part B, instead of beneficiaries with Part A or Part B, as it currently stands. CMS intends to issue a request for information on this topic.  

A CMS fact sheet is available with more information. Comments on Part I and Part II are due to CMS on Nov. 30. The final rate announcement will be published by April 5, 2021.