Summary of CY 2024 Proposed Rule for Medicare Advantage Organizations and Part D Sponsors
CMS released the CY 2024 Proposed Rule for MA and Part D sponsors on December 14, 2022, making significant changes to Medicare Advantage and Part D regulations.
Part B Drug Cost Sharing Adjustments Required for Medicare Advantage Plans in 2023
The Inflation Reduction Act provisions mandating adjustments to cost sharing for Part B drugs subject to inflationary rebates were silent on the question of whether Medicare Advantage (MA) plans would need to adjust coinsurance for drugs subject to inflationary rebates for the previous quarter. On November 7, 2022, however, CMS released a memorandum titled, “Inflation Reduction Act Changes to Cost Sharing for Part B Drugs for Contract Year 2023 Medicare Advantage and Section 1876 Cost Plans.”
CMS Buys More Time to Finalize MA Risk Adjustment Rule
Last Friday, CMS took a three-month extension to finalize the 2018 proposed rule that would have revised Risk Adjustment Data Validation (RADV) regulations to make it easier for the government to recoup overpayments to Medicare Advantage (MA) organizations, including use of extrapolation based on the error rates in audit samples.
CMS Issues Medicare Advantage Marketing FAQs
On October 19, 2023, CMS released FAQs on the updated marketing requirements that are in place this annual open enrollment season. CMS clarified its expectations under the regulations for third party marketing organizations (TPMOs).
Elizabeth Lippincott will Co-Chair and speak at American Conference Institute’s (ACI) Legal, Regulatory and Compliance Summit on Medicare Advantage
October 12- 13, 2022 Nashville, Tennessee Elizabeth Lippincott will co-chair and speak at ACI’s Legal, Regulatory and Compliance Summit on Medicare Advantage from October 12-13, 2022, in Nashville, Tennessee. Elizabeth’s co-chair is Karen Lam of Kaiser Permanente. Elizabeth will be presenting alongside Teresa A. Mason of Epstein Becker Green and Julie Nielsen of Berkeley Research Group discussing "Risk Adjustment: Forecasting the Future of Enforcement and the Implications for the Compliance and Legal Landscape."
Top of Mind Tuesday: Congress Passes Bill with Major Implications for Medicare Plans
The Senate and House of Representatives voted to pass the Inflation Reduction Act (IRA), a major budget bill impacting environmental, tax, and health policy, which is expected to be signed into law shortly. The bill contains numerous changes relevant to Medicare and the ACA, but most notably for Medicare prescription drug plans, the IRA will allow Medicare to negotiate prescription drug prices for a limited number of medications.
Top of Mind Tuesday: New Third-Party Marketing Requirements for Medicare Advantage
CMS published new marketing and communications requirements, which went into effect June 28, 2022, impacting Medicare Advantage (MA) organizations. The new requirements are intended to address beneficiary complaints associated with third-party marketing organizations (TPMOs), as well as feedback from beneficiary advocates and stakeholders concerned about the marketing practices of TPMOs that sell multiple MA and Part D products.
Medicare Advantage Snapshot – Going Strong in 2022
In 2005, the year I started focusing my practice on Medicare plans, fewer than 14% of Medicare beneficiaries, or roughly 6 million people, were enrolled in Medicare managed care products. By the end of 2021, more than 26 million people, or 42% of Medicare beneficiaries, were in Medicare Advantage, and more than 46% of Medicare spending flows through this program. Basically, in the last 17 years, Medicare Advantage transitioned from being a niche managed care option towards becoming the standard way that Americans receive their Medicare benefits.
CMS Proposes Regulatory Changes to Medicare Advantage and Part D
If you, like us here at SHL, have been waiting for insights into the Biden Administration’s vision and agenda for the Medicare Advantage and Part D programs, the wait is over. On Thursday, January 6, CMS proposed Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs, [CMS-4192-P]. Comments on the proposed rule are due March 7, 2022. We encourage health care companies to comment individually on their highest priority issues in addition to contributing to comment letters submitted by industry associations.
Strategic Health Law’s Top of Mind Tuesday: Changes in Gift Card Guidance
Guidance from the Office of Inspector General (OIG) and Centers for Medicare & Medicaid Services (CMS) imposes restrictions that go beyond the long-standing prohibition on Medicare Advantage (MA) organizations offering cash or cash equivalents as reward items or nominal gifts.
