C-TAC Comments on Recent CMS Request for Information on Medicare Advantage

As part of our ongoing dialogue with the Centers for Medicare and Medicaid Services, CMS, C-TAC recently submitted comments on their request for information (RFI) on the Medicare Advantage (MA) program.

Enrollment in MA, the form of Medicare administered by private health plans, has grown to almost 50% of Medicare beneficiaries and so must provide quality care to all enrollees and especially those with serious illness. In this RFI, CMS asked for input on how to improve various aspects of the MA program and C-TAC commented as part of our efforts to influence federal policy on behalf of those living with serious illness. Here are the areas C-TAC commented on:

Advancing Health Equity

• Demographic groups– We appreciated mention of those “enrollees with disabilities, frailty, other serious health conditions, or who are nearing end of life” in the RFI as among the key demographic groups CMS wants to gather more information on.
• Palliative care– We noted that palliative care has particular potential to advance health equity through comprehensive assessment and interdisciplinary team-based care and cited successful palliative care programs involving diverse populations.
• Screening for social risk factors– We suggested that family caregivers be assessed for their own social risk factors and burden as they can impact many aspects of the care experience for their loved ones. We suggested also including symptom assessment in future MA screening as there are inequities in pain experience and care in communities of color.

Driving Innovation to Promote Person-Centered Care

• Value-based contracting– We noted that such contracting can be difficult to participate in for providers from under-resourced communities and suggested upfront investment and payment adjustment to help those in marginalized communities be able to develop sustainable processes, information technology systems, and the reporting mechanisms needed to handle the financial risk of value-based contracting.
• Value-based Insurance Design (VBID) Model- Hospice Benefit Component– We confirmed our support of this aspect of the VBID model and expressed hope that it be executed so that the evaluation is robust enough to allow for expansion if successful.

Supporting Affordability and Sustainability

• MA and end-of-life (EOL) care– We noted that with MA soon to become the dominant form of Medicare delivery, we were particularly concerned about issues raised in last summer’s GAO report on MA beneficiary disenrollment at the end of life that found “MA beneficiaries in the last year of life disenrolled at more than twice the rate of all other MA Beneficiaries.” We noted this is also a health equity issue and suggested adding measures that track MA end-of-life disenrollment and hospice referral as a start.

Engaging Partners

• Continuum of care approach– We noted that serious illness care is ideally structured as a continuum of services. We pointed out that current regulatory and policy frameworks often artificially separate different components of serious illness care, such as specialty care, advance care planning, palliative care, and hospice, and encouraged federal partners to support policies, programs, and guidance that tether these programs and concepts together, to create a supportive system of care for individuals with serious illness. We also encouraged additional guidance to providers about the appropriateness of palliative care and hospice for people with serious illness along with recommendations for when to refer beneficiaries to such services.

Geographic demographic performance data– We suggested gathering and reporting information to show an MA plan how their programs perform on a demographic population basis versus the demographics of their specific service area to identify any gaps.