Sarah Aillon

FAH Comments on 2024 Medicare Advantage Program

FAH submitted comments to the Centers for Medicare &Medicaid Services (CMS) on the proposed rule on Contract Year (CY) 2024 Medicare Advantage (MA) and Part D Policy and Technical Changes and Medicare Parts A, B, C, and D Overpayment Proposed Rule (Proposed Rule). The largely focused its comments on CMS’ proposals geared toward addressing deficiencies in MA enrollees’ access to basic benefits and use of prior authorization. If finalized, many of the proposals in the rule make good headway in addressing concerns raised by FAH and our Medicare Advantage advocacy goals. 

Specifically, FAH applauds the proposed amendments explicitly requiring MA plans to cover services covered under Traditional Medicare, including the two-midnight rule for inpatient hospital care and the Medicare coverage criteria for skilled nursing facility (SNF) care, Home Health services, and Inpatient Rehabilitation Facility (IRF) admissions.  FAH also supported proposals to significantly limit internal and proprietary coverage criteria of plans and to require the creation and use of a Utilization Management Committee to address coverage issues.  The letter also addressed network adequacy, downcoding, overpayments, and several other issues.

A copy of the 27-page letter is available here.