AMGA Supports CMS Medicare Advantage Supplemental Benefit Proposal

Alexandria, VA –AMGA today expressed support for the Centers for Medicare & Medicaid Services’ (CMS’) proposal in its CY 2019 Medicare Advantage (MA) Advanced Notice to reinterpret its guidance to expand the scope of supplemental benefits that MA plans may offer. Value-based models of care are based on keeping patients healthy, and AMGA supported CMS’ effort to allow plans to cover items and services that enhance beneficiaries’ quality of life and improve health outcomes in comments to the agency.

“Medicare Advantage increasingly represents a pathway to value-based care,” said  Jerry Penso, M.D., M.B.A., AMGA president and chief executive officer. “By providing flexibility in plan design and what type of benefits plans may offer, CMS is recognizing how providers and payers can work together to ensure patients have access to needed interventions that keep them healthy and not just respond to an acute illness or injury.”

The proposed expansion of supplemental benefits for MA plans is based on a revision to CMS’ definition of “primarily health related,” which was included in the agency’s CY 2019 Advanced Notice and Draft Call letter. AMGA provided detailed comments on a number of other provisions in the Advanced Notice, including the use of encounter data in calculating MA plan risk scores and changes to CMS’ Overutilization Monitoring System.

In its letter expressing support for the expansion of supplemental benefits, AMGA expressed concerns about using encounter data for risk scoring. Last year, the Government Accountability Office identified problems with the accuracy of encounter data and AMGA recommended that the timeline for transition to encounter data in MA risk scoring be delayed. CMS agreed, and subsequently for 2018 reduced the percentage blend for MA risk adjustment so that it consists of 15% encounter data system (EDS) and 85% Risk Adjustment Payment System (RAPS) data. Now, CMS is proposing to modify the weight of EDS to 25% and RAPS to 75% for 2019. Although CMS has agreed to institute a number of reforms to address the accuracy of the encounter data, AMGA remains concerned that CMS is moving too quickly to rely on encounter data.

CMS also is proposing changes to its prescription drug monitoring system as part of an effort to address the opioid epidemic. AMGA supports these improvements and stands ready to work with CMS and other officials to develop best practices and guidelines on how to best ensure patients have access to needed pain medication while also addressing this public health crisis.

AMGA will closely review the final MA call letter.

AMGA’s letter on the proposed Advanced Notice is available on our website.


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.


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