iYesterday afternoon the U.S. Department of Health and Human Services Centers for Medicare and Medicaid Services (CMS) released its 2015 Medicare Advantage Rate Announcement and final Call Letter.
The final Call Letter announces a 0.4% increase in Medicare Advantage rates in 2015. The announcement comes after considerable lobbying efforts and Congressional requests in response to a significant rate cut proposed in CMS’s Advance Notice and draft Call Letter. According to CMS, the rate increase is due to policy changes that, taken in combination, allow Medicare Advantage benchmarks to increase rather than decrease.
In addition to the slight increase in capitation rates, the final Call Letter clarifies that, for 2015, CMS is not finalizing its proposal to exclude, for payment purposes, diagnoses identified during a home visit that are not confirmed by a subsequent clinical encounter.
The final Call Letter also requires Medicare Advantage Organizations (MAOs) to provide CMS with at least 90 days’ notice prior to network changes for any no cause termination deemed significant by the MAO. According to CMS, this requirement helps ensure compliance with provider access requirements. MAOs are also required to submit, upon request, a plan outlining: (1) the steps the MAO will take to ensure affected enrollees are able to locate new providers that meet individual needs and (2) how continuity of care would be maintained.
In addition, substantial mid-year provider network terminations initiated by an MAO without cause may, according to CMS, justify a special enrollment period. CMS’s analysis of whether to initiate the special enrollment period is based on a number of factors, including: (1) the number of enrollees affected; (2) the size of the service area affected; (3) the timing of the termination; (4) whether adequate and timely notice is provided to enrollees; and (5) any other relevant information.
For more on the finalized rates and proposals, including delayed implementation of the Part D Risk Adjustment Model and delayed changes to the Star Ratings, please see the final Call Letter fact sheet available here.
