Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Program for Contract Year 2024
2023-02-13 2023-02-13 2023-02-13 2023-02-13 2023-02-13 2023-02-13 2023-02-13 2023-02-13 2023-02-13 2023-02-13
CMS-2022-0191-0253 CMS-2022-0191-0301 CMS-2022-0191-0287 CMS-2022-0191-0280 CMS-2022-0191-0327 CMS-2022-0191-0282 CMS-2022-0191-0319 CMS-2022-0191-0240 CMS-2022-0191-0248 CMS-2022-0191-0345
05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00
https://api.regulations.gov/v4/comments/CMS-2022-0191-0253 https://api.regulations.gov/v4/comments/CMS-2022-0191-0301 https://api.regulations.gov/v4/comments/CMS-2022-0191-0287 https://api.regulations.gov/v4/comments/CMS-2022-0191-0280 https://api.regulations.gov/v4/comments/CMS-2022-0191-0327 https://api.regulations.gov/v4/comments/CMS-2022-0191-0282 https://api.regulations.gov/v4/comments/CMS-2022-0191-0319 https://api.regulations.gov/v4/comments/CMS-2022-0191-0240 https://api.regulations.gov/v4/comments/CMS-2022-0191-0248 https://api.regulations.gov/v4/comments/CMS-2022-0191-0345
Sara Cindy Anonymous Anonymous Russell Anonymous Anonymous Patricia Anonymous Karen
Dean Thomas Anonymous Anonymous Jackson Anonymous Anonymous Morris Anonymous Polacheck standifer
I am writing as a concerned Independent Agent, who cares about my clients and the means to which I can help them find the best Medicare Supplement option for their specific needs. Adding more and more regulations to agents AS A WHOLE will only be to the detriment of my clients and potential clients. Independent Agents are not the same categorically, as those at a large call center who are simply badgering Medicare Beneficiaries. They certainly dont care about the individuals they are calling. They just want to convince them to sign up for their product. These are the agencies  you need to be regulating. NOT the Independent Agencies who actually HELP their clients. Adding more regulations, such as recording phone calls (2023 regulation) and 48 hour Scope of Appointments (proposed for 2024) will only hinder our ability to help our current clients and potential clients. We actually know our clients in most cases. We knew them when they were  our clients for the Marketplace or an employee for one of our group clients. We know their health history and we take the time to go over what medications they take, to be sure they get the best supplements for their specific needs. We will no longer be able to do that with our hands tied! Please take these concerns into consideration for the current and proposed regulations. Please consider separating the regulations imposed on Independent Agencies vs the Large Call Centers who are cold calling beneficiaries without consent. They are the big bad wolf you are looking to tie up, not me! Prior authorization policies should only be used to confirm the presence of diagnoses. They should not be used to predetermine the necessary length of stay or for preadmission coding.  MTM Eligibility - We oppose lowering the cost threshold to the average annual cost of 5 generic drugs. Decreasing the cost threshold to one fifth of what the 2023 threshold is, will greatly increase the number of MTM eligible members, which again, is a significant financial impact to plans. The increased administrative cost will result in increased member premiums, copays and deductibles and will not result in more robust plan benefits to offer members.We request some additional clarification and details on the proposed updated annual cost threshold methodology to fully understand the impact of this change. Will the methodology utilize the top 5 utilized generic drugs by prescription volume? Or the top 5 generic drugs by cost (i.e., plan paid amount)? Will this include/exclude generic specialty medications, that may be outliers in terms of cost compared to other non-specialty generic medications? Will there be a process to detect outlier NDCs to ensure they are not included in the average AWP calculation? Is the cost per 30-day supply of medication?  We would like clarification on how the adherence measures will be excluded from the CAI adjustment. Our understanding is that the CAI adjustment looks at the total population of the plan and calculates the percentage of low income, dual eligible, and disabled members. It is unclear how excluding the adherence measures would be applied to the calculation. Furthermore, we are concerned with the impact of implementing risk adjustment to the adherence measures. For the diabetes adherence measures, the change had an adverse effect on the rating. I support you efforts to make MA plans more closely align their coverage decisions with traditional Medicare.   Regarding Guardrails - We feel that removing the guardrails will lead to unpredictability which will hurt plans ability to budget and plan. While we understand that Tukey is meant to remove outliers and limit large swings, we feel keeping the guardrails in place will act as a guarantee. Page 58, Section H. Review of Medical Necessity Decisions by a Physician or Other Health Care Professional With Expertise in the Field of Medicine Appropriate to the Requested Service and Technical Correction to Effectuation Requirements for Standard Payment Reconsiderations ( 422.566, 422.590, and 422.629)Adverse Decision  appropriate expertise to deny  Is there more objective direction that can be provided to define this as it feels slightly subjective?  If you think direct mail during an election year is bad, you should see the volume of mail during Medicare Open Enrollment.  Just like a political campaign, it can be difficult at times for knowledgeable professionals to figure out the best health insurance product let alone a single, 85 year-old, childless widow with chronic health conditions.  Our hospital, Neosho Memorial, sponsored an unbiased educational program this year using SHICK counselors through the Area Agency on Aging. The attendees stories were desprate and heartbreaking.  CMSs policy and technical changes to Medicare Advantage Program is good for our elderly and their healthcare providers.  Please continue, you cannot underestimate the difference they will make in helping our patients simply make better choices AND receive the health services they believe they are paying for.    I am an agent and mentor I teach agents how to own their own Medicare business. I read the deceptive marketing practices flourish in Medicare advantage Report by the finance committee. If you really look at the organizations that have the majority of complaints to CMS. You will find it is the robocallers, telemarketing, Television Advertising, radio advertising, and direct mail campaigns. These are the Third party organizations (TPMO), the problem is CMS and Ron Wyden Committee has lumped the above with Field agents and brokers. They are not the same and agents and Agencys do not advertise nor act to deceive consumers. You need to separate these bad actors from independent agents and Agencys. Independent agents are helping consumers understand Medicare and are local in their area helping consumers understand Medical Group Networks, Formularies, and how the plan works. We do not call without a permission to call or SOA. Independent agents should not be lumped into these bad actors that you talk about in your deceptive marketing report, you know who is to blame yet you are punishing agents and agency owners who are not part of these deceptive practices. Agents and Agency owners follow the rules set forth by CMS. We only help those who we meet in person who request our help. Agents and Agencies would be good with getting rid of TV advertising, radio, direct mail campaigns, telemarketing bait and switch. Please do not get rid of educational Events, permission to call and SOA we are out here helping not hurting our seniors. We want you to get rid of these people who blow up our customers phone promising the unrealistic freebies that dont exist. But please know it is not the independent agent or agencies. Your problem is people who dont even hold a license in the insurance industry the robocallers, telemarketers, TV ads and deceptive direct mail. Stop those and your complaints will end. Remember agents were the good guys! Patient advocacy letter