Rulemaking for MA 2019
On November 16, 2017, CMS released Medicare Advantage and Part D policymaking for CY2019. The CMS press release is here. The Federal Register website is here. The typeset rule will publish on November 28. The index for recent MA policy documents is here.
MA and Provider Enrollment. One change that will affect all Medicare Advantage providers: CMS pulls a rule, issued last fall, that would require all downstream MA providers to be enrolled in Medicare. Rather, CMS will only require that MA providers "not" be on a CMS preclusion/exclusion list. This applies to Part D as well.
Bringing VBID into General MA. Another change is that CMS will allow many features of "Value Based Insurance Design" (such as reduced copays for selected services) to occur within Medicare Advantage plans. However, plans are forbidden to advertise VBID features. They can respond to VBID questions if asked, making cross-plan research very difficult for patients.
Narrowing the Definition of Marketing. CMS is required to by statute to closely scrutinize "marketing" materials of MA plans. It will define this more narrowly so that only advertising directly aimed at driving a patient's plan selection will be "marketing."
Trade press on MA rulemaking at National Law Review here, Lexology here.
CMMI Demo for MA VBID Expands
Shortly thereafter, on November 22, CMS announced an expanded Demo Program for Value Based Insurance Design test models in 25 states. For example, diabetes patients might get free eye exams, though other types of patients wouldn't get free eye exams. For the MA-VBID expansion, see the press release here, the fact sheet here. More detailed policy documents and application guidance at the CMMI MA VBID homepage, here.
Trade press on CMMI VBID at Fierce Healthcare here, at Modern Healthcare here, at Becker's Hospital Review, here.
For a new November 27 article on VBID in general, Fierce Healthcare, here.
It would take a full time expert to dissect the differences between the VBID expansion proposed in annual rulemaking for all 2019 MA plans, versus the VBID expansion described at the CMMI website. Maybe one difference is that the CMMI expansion is already locked and loaded, but the rulemaking version for everyone might get delayed or derailed in notice-and-comment policymaking. But clearly, CMS is taking on VBID and promoting it across multiple policy channels. The new main arms of VBID are reduced copays for existing benefits, and creation of narrowly available special benefits only for certain patients. If the special benefits are outside of Traditional Medicare, they must also be treated as "special benefits"
Update: December 5, 2017: United Healthcare launches more VBID MA programs, here.
