Thursday, September 19, 2024

CMS Issues RFI: Consolidating MAC Jurisdictions

 The CMS Part A, Part B, MAC MAP has been the same for many years, since Palmetto won the "Cahaba" jurisdiction in 2017/2018.

CMS has released an RFI - request for information - about contracting some of the smaller remaining MAC areas.

Find the PDF here:

Find an article here.   Find the Sept 4 home page here.   Click on a link to see the 6 page PDF.  Respond by October 4 (see PDF).

Logistics

CMS mentions that current A/B MACs range from 4.6% to 14.7% in size (J8 vs JH).  Until now, CMS made awards so that no MAC entity had more than 26% of all the MAC jurisdictions.   With further consolidation, CMS may relax the 26% guideline.   However, it still wants to ensure there are multiple MAC contracts so that each eventual jurisdiction re-bid will have multiple offers and not just 1.  CMS provides 23 questions it seeks feedback on.  E.g.:  "What are the advantages and disadvantages of awarding MACs with longer period of performance [10y instead of 7y]?" 

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See AI summary below.

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Chat GPT 4 Article:
CMS's Request for Information on MAC Consolidation
and 10-Year Contract Periods

The Centers for Medicare & Medicaid Services (CMS) is exploring significant changes to the management of Medicare Administrative Contractors (MACs). A recent Request for Information (RFI) seeks industry input on consolidating existing MAC jurisdictions and extending contract award periods to a full 10 years. This potential shift aims to enhance program efficiency, stability, and innovation in the administration of Medicare services.

Background on MACs and Current Consolidation Efforts

Since the early 2000s, CMS has replaced former Medicare claims administration contractors with regional MACs. Currently, CMS contracts with seven companies to provide claims administration and other services across 16 MAC contracts. Four of these MACs focus on durable medical equipment (DME), while the remaining 12 handle Medicare Part A and Part B claims, with some also processing Home Health and Hospice (HH+H) claims.

The RFI outlines CMS's plans to consolidate certain MAC jurisdictions:

  • Jurisdiction 5 (J5) and A/B HH+H MAC Jurisdiction 6 (J6) into "Jurisdiction G".
  • Jurisdiction 8 (J8) and A/B HH+H MAC Jurisdiction 15 (J15) into "Jurisdiction Q".

These consolidations are part of a revisited effort that was previously paused in 2014 to promote long-term program stability and maintain a competitive pool of contractors.

Proposed 10-Year MAC Contract Award Period

Under the current structure, MAC contracts are awarded for a seven-year period (one base year plus six option years). CMS is considering extending this period to the full 10 years authorized under the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. The rationale behind this extension includes:

  • Long-term Investments: Longer contract periods could incentivize MACs to invest in innovations and efficiencies.
  • Performance Correlation: Historical data suggests longer contracts are associated with higher performance scores.

Key Areas for Industry Feedback

CMS is seeking input from stakeholders on several aspects of this proposed consolidation and contract period extension:

  1. Consolidation Considerations: CMS wants feedback on the benefits and challenges of consolidating J5/J6 into "Jurisdiction G" and J8/J15 into "Jurisdiction Q." This includes potential impacts on provider communications, system security, and subcontract transitions.

  2. 10-Year Contract Period: CMS is interested in understanding the advantages and disadvantages of extending contract periods to 10 years. They are also exploring ways to incentivize and reward exceptional MAC performance over a longer period.

  3. Impact on Workflow Systems and Innovations: The RFI seeks input on how consolidation and longer contracts might affect MAC workflow systems, innovation development, and enhancements.

Response and Confidentiality

The RFI is not a formal request for proposal (RFP) and does not commit CMS to award a contract. Interested parties are encouraged to submit their responses within 30 days of the RFI publish date. CMS has highlighted the importance of protecting proprietary information, indicating that submissions will be subject to Freedom of Information Act (FOIA) requirements unless protected under Exemption 4.

Conclusion

This RFI represents a pivotal moment for CMS and the broader Medicare administration landscape. The proposed consolidation of MAC jurisdictions and the extension of contract periods have the potential to reshape how Medicare services are administered, potentially improving efficiency, innovation, and the overall effectiveness of the Medicare program. Stakeholders in the Medicare policy space should closely follow these developments and consider contributing their insights to the ongoing discussion.