Skip to content

AV Submits Letter on Transparency and Accountability in Medicare Advantage

Arnold Ventures provided comments to the Centers for Medicare and Medicaid Services on Medicare broker incentives and integrated plans for the dually eligible.

Over the last two decades the Medicare Advantage (MA) program has grown rapidly, with nearly half of all Medicare beneficiaries – more than 30 million people – now enrolled in MA plans. Now more than ever, there is a need to hold MA plans accountable for delivering cost-effective and high-quality care, something many plans have fallen short of since the program’s inception. 

In November 2023, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule that makes some progress in addressing these missed marks. In it, CMS proposes certain changes that would strengthen guardrails to promote healthy competition in MA and improve care delivery and coordination for dual-eligible beneficiaries that opt to enroll in the MA program. In response to CMS’ proposals, we made the following recommendations for increasing transparency and accountability: 

  • Go further to address Medicare broker incentives and marketing tactics, which can influence the enrollment advice and information beneficiaries receive. We strongly support CMS’ proposed changes to align compensation incentives for Medicare insurance brokers and agents. The current approach to compensation can lead them to steer beneficiaries to certain plans based on profit rather than offering unbiased guidance that helps beneficiaries select a plan that best fits their needs. AV is recommending CMS consider additional reforms to align enrollment incentives between MA and traditional Medicare (Part D/​Medigap) and to protect beneficiaries from deceptive MA plan marketing tactics that undermine their ability to make informed coverage decisions. 
  • Continue to recommend integrated plans that serve people who are dually eligible for Medicare and Medicaid better coordinate their coverage. We applaud the focus on the dual-eligible special needs plan (D‑SNP), a specific type of MA plan intended to coordinate Medicare and Medicaid coverage for people who are eligible for both programs. Throughout the rule, CMS proposes changes that would result in increased integration and simplify the landscape of available coverage options.

The current proposals, if finalized, mark progress toward improving the experience of both those enrolled or seeking to enroll in these programs, and we urge CMS to largely finalize them as presented. However, the MA program still requires significant reforms to ensure it is financially sustainable for taxpayers and delivering for the people who rely on it. 

You can read our full set of recommendations based on CMS’ proposals here.