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.
