Sharon Grace
703.838.0033 ext. 393

February 2, 2017

AMGA Encouraged by CMS Willingness to Modify Medicare Advantage Encounter Data Risk Scoring

Alexandria, VA –AMGA is pleased that the Centers for Medicare & Medicaid Services (CMS) is not proposing to move forward with a more aggressive use of Medicare Advantage (MA) encounter data for risk adjustment as part of its Advance Notice of Methodological Changes for Calendar Year 2018 Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2017 Call Letter.

In our comments to CMS on the 2017 Medicare Advantage policies, AMGA emphasized the underlying flaws in moving toward a risk score that is based equally on encounter data.  This concern is shared by the Government Accountability Office (GAO), which in January 2017 reported that CMS has not made progress in its ability to “validate the completeness and accuracy” of MA encounter data.  As a result, GAO concluded that CMS “cannot appropriately risk adjust” MA payments. 

“This slowdown in the transition to encounter data is a welcomed development,” said Donald W. Fisher, Ph.D., CAE, AMGA president and chief executive officer.  “Accurate data is vital to ensuring payments are fair.”

CMS is seeking comment on the appropriate use of encounter data. AMGA will closely review the Advance Notice and how it addresses coding pattern adjustments, plan payment updates, and other issues that influence the ability of AMGA members to work with Medicare Advantage plans to provide coordinated, high quality care. We will submit formal comments by the March 3, 2017 deadline.

About AMGA
AMGA is a trade association leading the transformation of health care in America. Representing multispecialty medical groups and integrated systems of care, we advocate, educate, innovate, and empower our members to deliver the next level of high performance health. AMGA is the national voice promoting awareness of our members’ recognized excellence in the delivery of coordinated, high-quality, high-value care. More than 175,000 physicians practice in our member organizations, delivering care to one in three Americans. For more information, visit