AMGA Recommends Against Finalizing Risk Adjustment Changes
AMGA today recommended the Centers for Medicare & Medicaid Services (CMS) not move forward with its proposed changes to the Hierarchical Condition Categories (CMS-HCC) model, which informs payments to Medicare Advantage (MA) plans.
Alexandria, VA – AMGA today recommended the Centers for Medicare & Medicaid Services (CMS) not move forward with its proposed changes to the Hierarchical Condition Categories (CMS-HCC) model, which informs payments to Medicare Advantage (MA) plans. The Advance Notice comment period offers little time to model and analyze a major change to risk adjustment in the MA program. In addition, AMGA disagrees that removing codes from the HCC model addresses discretionary coding variation, but instead would remove distinct clinical differences from the model. CMS should not move forward with its proposed change until stakeholders understand what the impacts of these changes will mean to MA plan design and care delivery, particularly to patients with chronic conditions such as diabetes and congestive heart failure.
“Modifying the HCC model is not a simple technical update or revision,” said AMGA President and CEO Jerry Penso, MD, MBA. “It’s likely to have significant ramifications, affecting both plans and providers. CMS should recognize that stakeholders can’t provide substantive, constructive feedback in such a short timeframe.”
In addition, AMGA endorsed a proposal to align quality measurement across Medicare. The CMS Universal Foundation measurement proposal is similar to an AMGA 2018 initiative, which developed a streamlined set of quality measures designed to simplify the reporting process and limit the burden on providers and group practices, while still reporting clinically relevant and actionable data.
“AMGA members report hundreds of measures to a variety of payers, often with little to no actual clinical benefits,” Penso added. “CMS’ recognition of this issue and willingness to rethink how Medicare uses quality measures are a welcome development.”
In 2018, AMGA selected a core set of 14 measures to address the flaws with the current quality measurement and reporting system, which suffers from duplicative measures and a lack of data standardization. AMGA is pleased that CMS has endorsed this concept in its 2024 Medicare Advantage Advance Notice. As CMS continues to develop its Universal Foundation model, AMGA and its members are prepared to offer insights and support to this important work.
AMGA’s comments on the proposed rule are available on AMGA’s website.
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About AMGA
AMGA is a trade association leading the transformation of healthcare 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 amga.org