Comments on 2024 Medicare Part C and D Advance Notice

Doctor coding
Editor's note:

This comment letter is part of the USC-Brookings Schaeffer Initiative for Health Policy, which is a partnership between Economic Studies at Brookings and the University of Southern California Schaeffer Center for Health Policy & Economics. The Initiative aims to inform the national health care debate with rigorous, evidence-based analysis leading to practical recommendations using the collaborative strengths of USC and Brookings. This comment was submitted to the Centers for Medicare & Medicaid Services on March 6, 2023.

Matthew Fiedler commented on the risk adjustment provisions of the 2024 Medicare Part C and D Advance Notice published by the Centers for Medicare and Medicaid Services (CMS). Fiedler argues that CMS’ proposed changes to the Medicare Advantage (MA) risk adjustment model are likely to bring CMS closer to meeting its legal obligation to ensure that payments to MA plans are aligned with the claims risk of MA enrollees. He also says that CMS’ proposals to exclude from the model certain diagnoses that are more intensively coded in MA (or limit the role of those diagnoses) have advantages over other ways of addressing higher coding intensity in MA; however, CMS should be attentive to the risk of reducing the model’s predictive power and report how the changes affect measures of model fit, such as the model R².

Read the full comment letter here.

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