Media Center

FAH Statement | CMMI | Medicare | FAH Policy Blog Team

FAH Comments on CMS 2019 MA Draft Call Letter

FAH recently submitted a comment letter to CMS on the 2019 Medicare Advantage (MA) and Part D Advance Notice and Draft Call Letter. FAH urged CMS to use caution when allowing MA organizations (MAOs) greater flexibility regarding cost-sharing and benefit design (e.g., tiered cost-sharing, increased cost-sharing to manage utilization, and new interpretation of the uniformity requirements), as these changes could limit transparency and increase beneficiary costs and confusion.


The letter also expressed continued concern that MAOs inappropriately reclassify inpatient hospital stays as outpatient “observation” stays, as well as disappointment that CMS has not addressed network adequacy deficiencies, particularly with regard to sub-networks and post-acute care. Additionally, the letter urges CMS to: continue enforcement actions against MAOs for inaccurate provider directories; require MAOs to honor prior authorizations at the time of payment; require MA plans to inform providers about an enrollee's participation in the Qualified Medicare Beneficiary (QMB) Program; and undertake updates to the Star Ratings Program.

You can read the letter here.