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MLTSS Association Comments on CMS 2025 Advance Notice

On January 31st, 2024, CMS published the Advance Notice of Methodological Changes for Calendar Year (CY) 2025 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies. Among its changes, CMS proposes the continued phase-in of the significant risk adjustment model changes finalized last year and updates to the Part D risk adjustment model given the Inflation Reduction Act’s redesign of the Part D benefit. We provided CMS with comments on impacts to D-SNPs, including reiterating our past concerns on the risk adjustment model changes, highlighting concern of the proposed growth factor underestimating the reality of Medicare costs plans are experiencing, and noting the unique impacts the Part D risk adjustment changes may have on D-SNPs.  


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