Sharon Grace
Vice President of Public Affairs
703.838.0033 ext. 393

April 3, 2017

AMGA Supports 2018 Medicare Advantage Encounter Data Policy
Sees Opportunity for Congress to Address Coding Intensity, Benchmark Cap Problems

Alexandria, VA – AMGA is pleased the Centers for Medicare & Medicaid Services (CMS) further reduced the weight of encounter data in setting Medicare Advantage (MA) plan risk scores.

In its proposed “Advance Notice of Methodological Changes for Calendar Year 2018 Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2018 Call Letter,” CMS proposed to delay a planned increase in the weight given to the Encounter Data System (EDS) for risk scoring for MA plans. CMS recognized the problems with relying on EDS for risk scoring for MA plans by reducing it from 25% as proposed to 15% of the risk score calculation.

“It is important that any risk adjustment in MA is fair and accurate,” said Chet Speed, AMGA’s vice president of public policy. “With the flaws in the current Encounter Data System, CMS made the right choice in dropping the weight to 15%”

CMS also is implementing the minimum coding intensity adjustment as required by law. This adjustment is intended to account for differences in diagnosis coding between Medicare Advantage and fee-for-service.  For example, MedPAC has suggested using 2-years’ worth of diagnostic data to calculate risk scores, a suggestion CMS should consider.

“This is a problem that Congress can address with help from the stakeholder community,” Speed said.  “This year-to-year variation isn’t helpful, and a more equitable system should be explored.”

In addition to problems with the EDS, CMS in the proposed Advance Notice also highlighted the need to address the benchmark caps problem. Under current law, which CMS has cited in its inability to address the issue, MA plans in certain counties that demonstrate quality under the Medicare Star Rating System are not eligible for bonus payments, which can be used for offering additional supplemental benefits or reducing beneficiary cost sharing.

“Quality should be recognized, and a technical quirk in the law shouldn’t keep MA plans from forgoing bonuses they otherwise earned,” Speed said.

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. For more information, visit