A new analysis from Oak Street Health found the proposed 2024 MA advance notice could make it harder for providers to coordinate care for dual-eligible Medicare-Medicaid beneficiaries and people of color.1
The primary care center company conducted an internal analysis that suggests “some of CMS’ proposed changes may put underserved Medicare beneficiaries at risk for a disproportionate cut in their benefits.”
Dual-eligible members would see a $240 per member per year drop in risk-adjusted resources, compared with non-dual-eligible white members. Dual-eligible members who are also Black or African American would see a $480 per member per year cut in risk-adjusted resources, compared with non-dual-eligible white members.
Oak Street has urged CMS to instead:
- Increase demographic coefficients for dual-eligible beneficiaries. This would ensure more resources are available for this population and members with certain complex chronic conditions.
- Further increase disease coefficients for some chronic conditions, particularly for dual-eligible beneficiaries with those conditions. Currently, 39 conditions are reimbursed at a lower rate for dual-eligible beneficiaries than for those who are not dual-eligible.
- Revisit and reintroduce some of the removed codes in the proposed model. CMS has proposed removing more than 2,000 codes from MA’s risk adjustment model to address coding abuse, but the elimination of certain codes in five areas would cause “disproportionate reduction in payments for dually eligible patients.”1,2
- Add new coding for two major conditions with diagnoses that are more common in underserved communities.
Oak Street notes that any increased costs related to these recommendations could be addressed by moderate decreases in demographic coefficients for non-dual-eligible beneficiaries. Under the proposed rule, these would increase.
Both Oak Street Health and the Better Medicare Alliance also pointed to implications for value-based care, with BMA stating that reducing payments to MA plans and providers of coordinated care would be a setback to the movement.2 Oak Street noted that risk scoring should not become the key driver of success for providers of value-based care, as success should instead be driven by “keeping patients happy, healthy and out of the hospital.”
Multiple healthcare organizations have asked CMS not to finalize the proposal or to delay the proposed changes until further research is done on the potential impact.
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- Khan, A. Oak Street Health weighs in on 2024 Medicare Advantage rate notice. Oak St. Health. March 13, 2023. https://www.oakstreethealth.com/oak-street-weighs-in-on-2024-medicare-advantage-rate-notice-1191679
- Bailey, V. Stakeholder groups oppose Medicare Advantage risk adjustment changes. HealthPayerIntelligence. March 16, 2023. https://healthpayerintelligence.com/news/stakeholder-groups-oppose-medicare-advantage-risk-adjustment-changes