The Task Force Provides Input to CMS on CY 2023 Medicare Advantage Proposed Rule and Advance Notice

The Health Care Transformation Task Force filed two comment letters with HHS/CMS on proposed rulemaking for the CY 2023 Medicare Advantage program (CMS-4192-P), as well as the Advance Notice of Methodological Changes for Calendar Year 2023 for Medicare Advantage (CMS-2022-0021).


  1. Enrollee Participation in Plan Governance: The Task Force supports CMS’ proposal to require MA organizations that offer a D-SNP to establish at least one enrollee advisory committee (EAC) in each state, with recommendations that the final rule ensure that the EACs are established in a way that supports meaningful beneficiary participation.
  2. Standardized Housing, Food Insecurity, and Transportation Questions on the Health Risk Assessment: The Task Force supports CMS requiring that MA organizations incorporate social risk assessment questions into the HRA for D-SNP beneficiaries, with flexibility in the tools/questions used by MA organizations that have already started going down this path.
  3. Refining Definitions for Fully Integrated (FIDE) and Highly Integrated (HIDE) D-SNPs: HCTTF supports CMS’ efforts to clarify the definitions of FIDE SNPs and HIDE SNPs to create greater transparency of benefits for all beneficiaries.
  4. Special Requirements During a Disaster or Emergency: The Task Force supports CMS providing clarifying language on the criteria for determining when an MA organization no longer must comply with disaster or emergency special requirements.
  5. Network Adequacy Compliance at Application: While supportive of balanced network adequacy policies, the Task Force expresses concern about the proposal to require network adequacy compliance at the time an MA organization submits a service area expansion (SAE application).
  6. Star Ratings and Continued COIVD Impact: HCTTF supports the rationale for removing two Health Outcome Survey measures from the Star Ratings calculation, given the disruption COVID had on in-person visits that directly impact those measures.  The Task Force does recommends these measures be publicly reported to ensure attention is paid to these critical outcomes.

Read the Letter



  1. Normalization Factors: HCTTF recommends that CMS establish parity across all Medicare models and programs when it comes to capping risk score growth.
  2. Stratified Reporting (Part C and D): The Task Force supports CMS’ proposal to report difference in contract performance on additional Star Ratings measures for subgroups of beneficiaries with social risk factors.
  3. Health Equity Index: HCTTF supports proposals to create a Health Equity Index and new reward factor, but urges CMS to provide adequate time for MA plans to adapt.
  4. Measure of Contracts’ Assessment of Beneficiary Needs: The Task Force supports the development of a measure of whether plans are screening for and assessing enrollee’s health related social needs.
  5. Screening and Referral to Social Services: The Task Force supports CMS’ effort to use a National Committee for Quality Assurance measure to monitor plans’ screening and referral for beneficiaries with social needs.
  6. Value-Based Care (Part C): The Task Force welcomes CMS’ proposal to develop a future measure focusing on the percentage of MA plans that are in value-based contracts. The Task Force recommends that the measure use the Health Care Payment Learning and Action Network’s Alternative Payment Model framework.

Read the Letter