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Our Take on the 2019 Advance Notice and Draft Call Letter

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Yesterday, the Centers for Medicare & Medicaid Services (CMS) released Part II of the Advance Notice and Call Letter (ANCL), describing the Agency's proposed 2019 payment policies and other policy updates for the upcoming plan year for Medicare Advantage (MA) and Part D plans.

Comments to the proposed changes in the ANCL must be received by March 5, 2018.

At the end of 2017, CMS released Part I of the 2019 ANCL, which proposed changes to the MA risk adjustment model. Under the 21st Century Cures Act, CMS was required to make changes to the risk adjustment model and allow for a 60-day comment period. Comments for Part I of the ANCL are also due March 5, 2018.

The final ANCL will be released on April 2, 2018.

Avalere experts anticipate changes in the following areas:

MA and Part D Highlights

  • Updates on CMS initiatives to test innovations in MA and Part D plan design
  • Enhancements for Star Ratings in 2019 and beyond

MA Highlights

  • Changes in MA payment methodology
  • Updates to the national per-capita MA growth percentage (NPCMAGP) for aged and disabled enrollees
  • Changes in aged/disabled fee-for-service (FFS) United States per-capita cost (USPCC)

Part D Highlights

  • Changes in the Part D payment methodology
  • Updates to the standard and LIS Part D benefit parameters

“The Advance Notice and Call Letter provides us with an opportunity to learn about CMS’ priorities and direction for the year ahead,” said Sean Creighton, vice president at Avalere Health.  “While there is an increased focus on risk adjustment in Medicare Advantage due to a 21st Century Cures provision, we also expect further updates around Medicare Advantage and Part D plan design.  The next couple of years will be very exciting for health plans as the opportunities to innovate increase and enrollment continues to expand.”

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