The ERISA Industry Committee (“ERIC”) today submitted comments to a Request for Information (“RFI”) from the Centers for Medicare & Medicaid Services (CMS) regarding improvements to the Medicare program, specifically concerning the Medicare Advantage program.
In the response to CMS, James Gelfand, ERIC President, writes, “Many ERIC member companies continue to offer high quality health benefits for retirees, with a particular emphasis on Medicare Advantage (MA) offerings. As such, ERIC has a vested interest in ensuring that the MA program continues to thrive and improve, and our member companies have a number of thoughts and comments to improve the program.”
Key recommendations to CMS include:
- Working Directly with Employers — ERIC believes CMS can better support the stability of the program and value of MA plans by working directly with employers, and continuing to focus on growth, value, and innovation.
- Expanding Availability of Quality Ratings in its Hospital Quality Programs — ERIC encourages CMS to consider requiring all hospitals to collect disaggregated data by race, ethnicity, primary language, geographic location, socioeconomic status, gender identity, sexual orientation, age and ability status and immediately adopt and endorse The Office of the National Coordinator for Health Information Technology’s 2015 Edition standards for collecting disaggregated data for all hospitals and for all CMS quality programs to help address the health equity gap in MA and all CMS programs.
- Supporting the Expansion of Supplemental Benefits– In particular, ERIC calls on CMS to be aware of and evaluate new technologies and services that benefit patients, which should be considered as eligible MA supplemental benefits. One consideration ERIC proposes is for CMS to allow wearable medical devices to be covered through the core medical benefit of both traditional Medicare and MA plans, so patients’ health can be improved.
- Modernizing Policies related to Chronic Kidney Disease — ERIC urges CMS to modernize the Conditions for Coverage (CFC) for ESRD facilities to keep pace with innovations in self-care, home dialysis, and telehealth for dialysis patients, remove barriers and streamline regulations for home-focused providers to expand patient access to home dialysis and self-dialysis, and promote access to care through alternative delivery sites.
- Bolstering Prior Authorization Programs – ERIC calls on CMS to hold a dialogue with employers and employer groups about the value of prior authorization in the delivery of value-based care to MA beneficiaries, so that MA continues to deliver high-quality care and value to patients. ERIC adds that any limitations CMS considers on prior authorization in Medicare and MA, must be paired with reforms that protect patients, providers, plan sponsors, and the taxpayers.
- Expanding Telemedicine Policies – ERIC is pleased that Medicare and MA beneficiaries have updated telehealth policies, and urges Congress to allow the same policies to apply to the rest of our employees and their families, so they may also benefit. ERIC also recommends that CMS allow audio-only telehealth visits as valid encounters for the documentation of diagnosis codes used for the calculation of MA risk scores.
- Promoting Value-Based Care Arrangements – ERIC recommends that CMS take the proactive step of urging providers who participate in value-based reimbursement models via Medicare Advantage, to extend similar options to their private sector payers. ERIC also encourages CMMI to continue with its Accountable Care Organization Realizing Equity, Access and Community Health (ACO REACH) Model to further increase value-based care arrangements in Medicare and MA.
- Testing Centers of Excellence and Demonstration Projects – ERIC believes that Medicare should implement centers of excellence – either gradually starting with demonstration programs, or immediately based on already available data – so that Medicare beneficiaries can also have access to improved specialized care. Further, ERIC recommends that CMMI design and implement demonstration projects in a way that allows other payers, including large employers, to be active and full participants.
- Initiating Site-Neutral Payment Policies – ERIC believes that CMS can support affordability and sustainability by further expanding its site-neutral payment policies as outlined in the June 2022 MedPAC report, and by aligning payment for office visits across ambulatory care settings, which would reduce program costs and beneficiary outlays.
In conclusion, Gelfand offered to work closely with the CMS on MA policy and welcomed an open dialogue.
“We believe that new policies and improvements can be made through collaboration and teamwork and look forward to hearing from you on how best we can support the MA program.”
To read the full comments issued today by ERIC visit its website at https://www.eric.org/wp-content/uploads/2022/08/8-31-22-CMS-Medicare-RFI-ERIC-Response-1.pdf