Comments on the 2025 Notice of Benefit and Payment Parameters

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Editor's note:

The author submitted this comment letter on January 8, 2024.

Matthew Fiedler submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding risk adjustment proposals included in the 2025 Notice of Benefit and Payment Parameters, specifically: (1) the proposed changes to the American Indian and Alaska Native (AI/AN) cost-sharing reduction (CSR) adjustment factors; and (2) CMS’ decision to otherwise continue current policy regarding how CSR plan variants are handled in risk adjustment. He argues that while the proposed change to the AI/AN CSR adjustment factors would improve risk adjustment, it would be preferable to comprehensively reform how CSR variants are handled in risk adjustment to account for the fact that issuers are no longer directly compensated for providing CSRs.

Read the full comment letter here

  • Acknowledgements and disclosures

    The author gratefully acknowledges helpful comments from Richard Frank and excellent research assistance from Chloe Zilkha.

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