Considerations as you Plan for 2022

As we patiently wait to see the new administration blossom, especially the continuing wonder about who will take the helm of the Centers for Medicare and Medicaid Services (CMS), let’s review some things that we know that should help inform the variety of decisions you make for 2022 planning. As you read, consider that doing the bare minimum will set you apart from your competitors – in the wrong direction.

CMS’ final Medicare Advantage (MA) and Part D Rate Announcement was released early so that organizations can plan ahead bid-wise, those of which are due on June 7. In the Advance Notice, CMS outlined an expected rate increase of 2.82%. However, based on a number of factors including effective growth rate and the finalization of the average geographic adjustment index, the expected average change in revenue leaped to over 4%.

The agency is enhancing Part C and Part D in a variety of ways. If you dig into the final rule CMS-4190-F2 published today, there is a lot to consider for future planning. There is always great insight in the CMS response to industry comments, so sit back with some tea and enjoy it. Supplemental benefits policy has been codified, including Chapter 4 criteria for a supplemental benefit and an expanded definition of “primarily health related.” The revised uniformity requirements were also finalized. CMS states access to supplemental benefits tied to a health status or disease state provided in a manner that ensures similarly situated individuals are treated uniformly is indeed consistent with the uniformity guideline. Over time, CMS established their authority to permit MA organizations the ability to reduce cost sharing for certain covered benefits, including these supplemental benefits described.  This should open the doors further for organizations designing their 2022 offerings. A word of advice: make sure you nail down your organization’s criteria for “similarly situated,”  that is, which enrollees meet the identified criteria for the supplemental benefits you will provide. 

According to a recent KFF article, almost 8 out of every 10 MA enrollees (not including special needs plans, employer group plans, and the like) are in plans with quality ratings of 4 or more stars. It has taken a few years to arrive at this figure, noting this figure was only at 62% five years ago. You could say that because of CMS’ commitment to the quality ratings program and in spite of the carousel of annual changes to the specifications, more enrollees are being drawn to high-performing plans. Certainly other elements factor into this, including mergers and acquisitions, savvy marketing, and attractive benefits. 

CMS’ flexibilities on telehealth spurred on by the public health emergency have helped plans continue care, but adoption of telehealth still has a way to go – not just for patients, but also for providers. I love seeing this telehealth certification course being offered to address how to deliver skilled telemedicine services, but something like this is not mandatory. Might that change in the future? I would personally love to see these programs flourish since telehealth is here to stay.