In a comment letter, Arnold Ventures urges the Centers for Medicare and Medicaid Services (CMS) to continue strengthening the risk adjustment system to curb upcoding-driven overpayments and promote competition. AV strongly supports CMS’ proposal to remove from risk adjustment chart review-based diagnoses that are not tied to medical encounters or services — an important step that would reduce overpayments due to upcoding and limit insurer gains from systemic gaming.
AV also calls for additional risk adjustment reforms, including removing diagnoses collected via in-home health risk assessments (HRAs), using two years of diagnostic data from both MA and traditional Medicare, and continuing to identify and exclude the most often gamed diagnoses.
Finally, AV encourages CMS to apply a higher coding adjustment factor than the statutory minimum in a way that targets plans that code most intensely, and to pursue larger-scale methodological reforms to improve the fiscal sustainability and integrity of the Medicare program and to ensure MA delivers value to beneficiaries and taxpayers.
