26 Jan The Task Force Submits Comments to CMS on the CY 2027 Medicare Advantage and Part D Proposed Rule
Posted at 10:56h
in Policy Communications
The Health Care Transformation Task Force (HCTTF) submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the Contract Year 2027 Medicare Advantage and Part D Proposed Rule (CMS-4212-P). The Task Force’s letter focuses on strengthening Medicare Advantage policy to promote high-quality, value-based care while preserving program stability, predictability, and beneficiary access. HCTTF’s letter focuses on the following topics:
Medicare Advantage/Part C and Part D Prescription Drug Plan Quality Rating System
- MA Star Ratings Measure Removals: HCTTF is broadly supportive of CMS’ efforts to streamline the Star Ratings measure set by retiring administratively burdensome and topped-out measures and refocusing the program on meaningful outcomes. The Task Force supports the addition of a depression screening and follow-up measure, while urging careful attention to technical specifications, implementation feasibility, and alignment with existing clinical workflows.
- Program Stability and Predictability: HCTTF cautions against the pace and scale of proposed measure removals, noting that rapid turnover risks undermining predictability for plans and providers.
Improvements for Special Needs Plans
- Oversight and Care Integration: HCTTF supports CMS’ focus on strengthening oversight and improving care integration within the SNP program while preserving the distinct statutory roles of C-SNPs, D-SNPs, and I-SNPs.
- Dual-Eligible Special Needs Plans (D-SNPS): HCTTF raises concerns about the growth of dual-eligible enrollment in C-SNPs and supports guardrails to protect integrated care models.
Request for Information (RFI): Future Directions in Medicare Advantage
- Risk Adjustment – Transparent and Phased Implementation: HCTTF emphasizes that any changes to the MA risk adjustment model should be introduced gradually and transparently with sufficient lead time, to allow plans and providers to adapt without disrupting beneficiary access or care delivery.
- Risk Adjustment – Alignment with Fee-for-Service Medicare: HCTTF encourages CMS to maintain methodological alignment between MA and FFS risk adjustment to promote consistency, fairness, and program integrity across Medicare.
- Risk Adjustment – Recognition of High-Need and Complex Populations: HCTTF underscores the importance of ensuring that risk adjustment continues to accurately capture clinical complexity, particularly for beneficiaries with multiple chronic conditions and functional or cognitive impairments.
- Risk Adjustment – Administrative Burden and Data Accuracy: The Task Force urges CMS to minimize additional documentation and coding burden on clinicians and to prioritize data accuracy and clinical validity over volume-driven reporting requirements.
- Quality Bonus Payments – Variability: CMS should continue to eliminate topped-out process measures and measures subject to substantial year-over-year variation outside of plan control.
- Quality Bonus Payments – Payment Timeline: HCTTF encourages CMS to consider ways to reduce lag time and improve alignment for incentive payments across organizations.