In a comment letter to the Centers for Medicare & Medicaid Services (CMS), Arnold Ventures
recommends reforms to Medicare Advantage (MA) to strengthen program integrity and competition by
realigning incentives toward cost-efficient, high-quality care, and improve integration for dually eligible
beneficiaries. The letter calls on CMS to reduce MA overpayments, which amount to billions in excess
payments annually, by prioritizing improvements to risk adjustment and other reforms to address
insurer coding abuses. This includes advancing less gameable risk adjustment reforms, such as removing
diagnoses identified through health risk assessments (HRAs) and relying more on non-plan provided
data, and fully correcting for coding differences between MA and traditional Medicare. We also
recommend strengthening the MA Star Ratings and Quality Bonus Program to better reward meaningful
performance and improve beneficiary decision-making without increasing program costs or rewarding
gaming. And finally, CMS should address the proliferation of dual eligible enrollment in Chronic
Condition Special Needs Plans (C‑SNPs) by applying existing look-alike regulations and allowing states to
contract directly with all SNP types. Read the full letter below.
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