Medicare Advantage and Part D Proposed Rule Comments

On March 7, 2022, the MLTSS Association submitted comments to CMS on the Medicare Program; Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs proposed rule.


The MLTSS Association supports CMS’ broad vision of continuing to further integrate Medicare and Medicaid plans, advancing health equity, and improving the beneficiary experience. While we appreciate the directional intent of CMS in this proposed rule, we believe that the proposed policies in this rule should be coupled with guardrails and incremental steps to mitigate against potential unintended consequences. Described in more detail in our letter, we recommend CMS:

  • Provide additional guidance on the implementation of enrollee advisory committees, including confirmation of flexibilities afforded to enrollees in participating (e.g., teleconferencing)

  • Allow for increased flexibility in its proposal to standardize social risk factor questions in HRAs to minimize duplication and leverage existing data collection efforts plans have already implemented with state partners

  • Provide necessary supports to states to operationalize finalized policy changes to D-SNP integration requirements

  • Apply the frailty adjuster to all highly integrated products

  • Consider the unique financing, quality, and enrollment realities of D-SNP-only contracts

  • Facilitate data-sharing between plans and states for applicable integrated plans and coordination of Medicaid and MA supplemental benefits

  • Withdraw the MOOP limit provision

  • Work with states that wish to keep their MMP demonstration programs as they currently operate while identifying opportunities for program permanency