The Task Force Provides Input to CMS on CY 2024 Medicare Advantage and Part D Proposed Rule

The Health Care Transformation Task Force submitted comments on the Centers for Medicare and Medicaid Services (CMS) Medicare Advantage (MA) and Part D Proposed Rule (CMS-4201-P). The Task Force’s comments focus on policy proposals related to the Star Ratings program, Health Equity, Strengthening Translation and Accessible Format Requirements for Materials and Content, Utilization Management and Prior Authorization, and Behavioral Health. Task Force positions are summarized below:

  1. STAR RATINGS PROGRAM HEALTH EQUITY INDEX: Consistent with recommendations submitted to CMS last year on the Medicare Advantage Advance Rate Notice, the Task Force supports the proposed Health Equity Index (HEI) reward. The letter does include recommendations for methodological changes to guard against unintended consequences in the reward’s design and implementation. The Task Force also comments on the proposal to replace the current reward factor with the HEI reward, noting the need for a phased-in process.
  2. PROVIDER DIRECTORIES:  HCTTF supports CMS’ proposal to require providers include data on their cultural and linguistic capabilities in the MA provider directory, to allow beneficiaries access to information that supports receipt of culturally congruent care.
  3. UNDERSTANDING BENEFICIARIES’ DIGITAL LITERACY: The Task Force is in favor of CMS’ proposal to require MA organizations to screen their beneficiaries’ level of digital health literacy, defined as “the ability to seek, find, understand, and appraise health information from electronic sources and apply the knowledge to addressing or solving a problem.”   With the growth in telehealth-based care, it is critical that MA organizations screen their members to identify opportunities to improve access and the ability to use information.
  4. STRENGTHENING TRANSLATION AND ACCESSIBLE FORMATS FOR MATERIALS AND CONTENT: CMS proposed several requirements related to improving access to materials and content for beneficiaries whose primary language is not English.  The Task Force supports these proposals, but recommends CMS develop an implementation plan that reflects the longer timeline potentially needed for MA plans to translate non-standardized communications, particularly for complex requests (e.g. foreign-language brail).
  5. UTILIZATION MANAGEMENT AND PRIOR AUTHORIZATION: In recognition that MA prior authorization requirements are creating undue burden for patients, the Task Force expresses support for proposals that have the effect of establishing clearer expectations and guardrails in pursuit of the goal of avoiding inappropriate denials.
  6. MA and Part D Marketing: The Task Force supports CMS’ proposals to create greater transparency of information available to MA enrollees, including restricting the use of superlatives in marketing materials without substantiating supporting data; prohibiting misrepresenting “savings” to beneficiaries on prescription drugs, and requiring simplification of plan comparisons, among other proposals.
  7. BEHAVIORAL HEALTH: The proposed rule includes a number of proposals by CMS to address the challenge of increased need for behavioral health services, coupled with the shortage of behavioral health work force.  The Task Force supports a number of these proposals, and provides recommendations regarding implementation, in light of said workforce shortage concerns.


Read the Letter