AMGA Statement on 2021 Medicare Advantage Advance Notice

Alexandria, VA – AMGA today recommended that the Centers for Medicare & Medicaid Services (CMS) ensure the Medicare Advantage (MA) program provides the reimbursement needed to care for patients with end stage renal disease (ESRD). In comments on the CY 2021 Advance Notice, AMGA noted its concerns with the methodology for setting payment rates for ESRD patients, who as of 2021 will have the option of enrolling in MA. AMGA believes that patients with ESRD will benefit from the MA program, but the benchmarking and payment methodologies should accurately reflect the costs of caring for this vulnerable population. Setting MA benchmarks for ESRD patients at the state level may not account for variations in costs across a state.

"Patients with ESRD stand to benefit from the care coordination, supplemental benefits, and the out-of-pocket costs protections that Medicare Advantage offers,” said AMGA president and CEO Jerry Penso, M.D., M.B.A. “That said, it is critical that the funding mechanism is structured correctly, so that plans and providers have the resources to care for this critically ill, and frankly, expensive patient population."

By including ESRD in MA, all patients will benefit from the chronic disease management that AMGA members provide. By managing chronic disease, including chronic kidney disease, across the continuum of care, AMGA members will work to prevent kidney disease from progressing to ESRD. Patients who do advance to ESRD will continue to have access to a benefit package that supports our members’ care delivery models, which are designed to manage chronic diseases.

AMGA also recommended that CMS work to ensure that encounter data is accurate, so that the risk scores based on the data are calculated correctly.

AMGA is continuing to review CMS’ proposed rule for the 2021 MA plan year and will be submitting detailed comments by the April 6, 2020, deadline.

AMGA's full recommendation letter is available here.


About 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.


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