In April 2011, revised coding guidelines for Alzheimer’s disease dementia  were issued, which raised new concerns for CMS that diagnosing  Alzheimer’s disease dementia may be more discretionary. Effect of Revised Community Model on Payment Accuracy Varied for High-Risk Groups Studied

In our comparison of the current and revised community models, the  revised community model slightly reduced the accuracy of MA payment  adjustments for beneficiaries with multiple chronic conditions—one of  three high-risk groups in our study. Specifically, the revised community model reduced the  accuracy for beneficiaries with at least two chronic conditions by $164,  which was about 1 percent of average actual expenditures. While the revised community model reduced the accuracy of MA payment  adjustments for beneficiaries with multiple chronic conditions as a whole,  this model improved the accuracy for the 4 percent of community FFS  beneficiaries with six or more chronic conditions by $727 or 2 percent of  average actual expenditures. 1.) Within the low-income group,  estimates from the revised and current community models were similar  for beneficiaries who received the Part D LIS but were not dually eligible  for Medicare and Medicaid, with the revised community model slightly  reducing accuracy by $28, or less than 0.5 percent of average actual  expenditures. C-SNP New Enrollee Model Substantially Improved Accuracy of MA Payment Adjustments, but Considerable Inaccuracy Remains for Certain Groups

Compared with the general new enrollee model, the C-SNP new enrollee  model substantially improved the accuracy of estimated health care  expenditures, and therefore of MA payment adjustments, for C-SNP- eligible new enrollees but still underestimated expenditures for certain   Specifically, the C-SNP new enrollee  groups by considerable amounts.model underestimated expenditures for C-SNP-eligible new enrollees by  $1,461, while the general new enrollee model underestimated  expenditures for this group by $3,914—an improvement in accuracy of  $2,453, or about 25 percent of average actual expenditures. The amount  by which accuracy improved was similar across 14 severe or disabling  chronic conditions: $2,402 to $2,723 (a range which represented 7 to   24 percent of average actual expenditures). This result reflects the design  of the C-SNP new enrollee model, which increases the expenditure  estimates from the general new enrollee model by an amount that does  not depend on beneficiaries’ medical conditions. Despite the improved  accuracy both on average and for each of the 14 conditions, the C-SNP  new enrollee model still underestimated expenditures for beneficiaries  who had certain conditions, such as end-stage liver disease or stroke, by  more than $15,000. On the other hand, the C-SNP new enrollee model  improved the accuracy of estimated health care expenditures of C-SNP  eligible new enrollees with 4 or more severe or disabling conditions by  $2,521, or about 8 percent of actual average expenditures. However, the  C-SNP new enrollee model still underestimated expenditures for this  group by over $20,000. Concluding Observations

Accurately adjusting payments to MA plans is important to help ensure  that these plans have the same financial incentive to enroll and care for  beneficiaries regardless of their health status or the resources they are  expected to consume. Whether CMS decides to  implement the revised community model that includes HCCs for dementia  will depend on CMS’s assessment of the advantage of more accurate  payment adjustment for beneficiaries with dementia compared with the  disadvantage of a potential increase in the discretionary coding of  dementia. However, the  model still considerably underestimated expenditures for new enrollees  diagnosed with four or more severe or disabling conditions, which could  place plans that disproportionately enroll these beneficiaries at a relative  financial disadvantage. In its comments, CMS suggested that the report include an assessment  of the overall accuracy of the current risk adjustment model. While we  agree that an overall assessment of the model’s accuracy would be  useful, such an analysis was not within the scope of our work and would  have required additional data. Appendix I: Additional Potential Changes to the Medicare Advantage Risk-Adjustment Models

The Centers for Medicare & Medicaid Services (CMS) has been  conducting ongoing research on the Medicare Advantage (MA) risk- adjustment models to improve the models’ accuracy in estimating  expenditures for beneficiary groups. Comparing the Accuracy of General and C-SNP New Enrollee Models

To compare the accuracy with which the general and C-SNP new  enrollee models adjust payments for C-SNP-eligible new enrollees, we  measured the accuracy of the general and C-SNP new enrollee models  using the same method we used for comparing the accuracy of the  current and revised community models.
Why GAO Did This Study

The Centers for Medicare & Medicaid Services (CMS) pays plans in Medicare Advantage (MA)--the private plan alternative to Medicare fee-for-service (FFS)--an amount per beneficiary that is adjusted to reflect beneficiary health status. This adjustment, called risk adjustment, helps ensure that health plans have the same financial incentive to enroll and care for beneficiaries regardless of their health status. In 2010, CMS announced plans to revise the major medical conditions included in its principal risk-adjustment model--the community model--and add a model for new enrollees in chronic condition special needs plans (C-SNP), which target beneficiaries with certain severe or disabling chronic conditions. CMS began using the C-SNP new enrollee model in 2011, in place of the general new enrollee model, to adjust MA payments for new Medicare beneficiaries who enroll in a C-SNP. GAO was asked to examine the accuracy of these models for high-risk beneficiaries. Using data for a nationally representative sample of 2007 FFS beneficiaries, GAO computed the amount that expenditure estimates were above or below actual expenditures for 2007, the most recent data available at the time. GAO compared the accuracy of the current and revised community models for three high-risk groups: beneficiaries with multiple chronic conditions, with low income, and with dementia. GAO compared the accuracy of the general and C-SNP new enrollee models for new enrollees eligible to enroll in a C-SNP.

What GAO Found

The effect of CMS's revised community model on payment accuracy varied for the high-risk groups studied. Specifically, compared with the current community model, the revised community model slightly reduced the accuracy of MA payment adjustments for beneficiaries with multiple chronic conditions by $164, or about 1 percent of average actual expenditures. For beneficiaries with low income, the accuracy of the revised and the current community models was similar: estimates differed by $5, or less than 0.1 percent of average actual expenditures. For beneficiaries with dementia, the revised community model substantially improved the accuracy of MA payment adjustments by $2,674, or about 16 percent of average actual expenditures.
Compared with the general new enrollee model, the C-SNP new enrollee model substantially improved the accuracy of MA payment adjustments for new enrollees with C-SNP conditions, but considerable inaccuracy in the model's estimates remains for certain groups. The amount by which accuracy improved was similar across 14 severe or disabling chronic conditions: about $2,500. This reflects the design of the C-SNP new enrollee model, which increases expenditure estimates from the general new enrollee model by an amount that does not depend on beneficiaries' medical conditions. However, the C-SNP new enrollee model still underestimated expenditures for C-SNP-eligible new enrollees, on average, by about $1,500 and by more than $15,000 for beneficiaries who had certain conditions, such as end-stage liver disease or stroke. The C-SNP new enrollee model's results varied depending on the number of severe or disabling conditions the beneficiary had. Specifically, the model reduced the accuracy of estimated expenditures for new enrollees with only 1 severe or disabling condition by about 62 percent of average actual expenditures but improved the accuracy for those with 4 or more conditions by about 8 percent. However, the C-SNP new enrollee model still underestimated expenditures for beneficiaries with 4 or more conditions by over $20,000.
Accurate risk adjustment is particularly important for certain high-risk beneficiary groups that are more challenging and costly to treat and may benefit particularly from the coordination of care MA plans can provide. The decision to implement the revised community model that adjusts for dementia will depend on CMS's assessment of the advantages of more accurate payment adjustment for beneficiaries with dementia compared with the potential increase in the discretionary coding of dementia because of revised coding guidelines for Alzheimer's disease dementia published in April 2011. Additionally, while the introduction of the C-SNP new enrollee model improved the accuracy of payment adjustments for eligible new enrollees, on average, the model still considerably underestimated expenditures for certain groups, which could place plans that disproportionately enroll beneficiaries in these groups at a relative financial disadvantage.
In its comments on a draft of this report, CMS suggested that GAO assess the overall accuracy of the current risk adjustment model. GAO did not assess overall model accuracy because such an analysis was not within the scope of GAO's work and would have required additional data.