ACR Calls on CMS for Enhanced Transparency & Reporting Save

The American College of Rheumatology (ACR) has submitted its response to the Centers for Medicare & Medicaid Services (CMS) request for information (RFI) and feedback from stakeholders on how best to enhance Medicare Advantage (MA) data capabilities and increase public transparency.

“Given more than half of Medicare beneficiaries are now choosing Medicare Advantage plans, we applaud CMS for more closely examining this program and, in particular, its impact on those living with complex chronic and acute conditions—including many rheumatic diseases that require specialized expertise and care,” said Dr. Christina Downey, chair of ACR’s Government Affairs Committee. “More reporting and greater transparency around prior authorization processes, care quality, health equity, MA market competition, and prescription drug plans can inform CMS’ decision to implement policies that improve the system for physicians and the healthcare experience for patients.”

ACR notes in its response letter that, “for too long, prior authorization policies by MA-managed care plans have been burdensome and time-consuming and have delayed care for beneficiaries.” To begin addressing this issue, the ACR requests that CMS make publicly available certain metrics on prior authorization, including requests, denials, response rates, reasons for denials, and frequency of denials categorized by type of service. ACR also joined a similar request letter from the Regulatory Relief Coalition asking CMS to implement policies that remove prior authorization barriers to timely care.

ACR also asks CMS to collect and report metrics that would help to better evaluate care quality and outcomes, including value-based care arrangements and efforts to meet health equity goals. This reporting should evaluate potential care disparities faced by MA beneficiaries of color by looking at the prevalence of certain diseases, enrollment in low-rated plans, access to 5-star plans, care outcomes, and average annual premiums. Additional reporting on the percentage of MA beneficiaries under 65 would help paint a clearer picture of how plan design and features impact various populations.

Additionally, given the growth of MA plans, ACR requests that policies support a truly competitive healthcare market. Concerns about consolidation and its impact on quality-of-care prompted ACR to request CMS evaluate bidding figures from each MA plan on an annual basis juxtaposed to the Herfindahl-Hirschman Index score of the markets in which each MA plan operates. Both pre- and post-merger analyses should look at the changes in average annual premiums by the state of residence, plan type, calendar year, and the number of rheumatologists each MA beneficiary has in-network. Consolidation has driven many independent rheumatologists out of practice and limited beneficiaries’ access to care, particularly in underserved communities challenged with accessing a local rheumatologist.

Finally, ACR asks that CMS look specifically at MA prescription drug plans to evaluate their quarterly listings of medications MA beneficiaries have access to and the percentage of MA beneficiaries who reach their out-of-pocket limits every year. Policies that limit choice or increase the cost burden for patients often lead patients to ration their doses or even abandon treatment altogether; in fact, according to recent research, 70% of new patients opt out of filling their prescriptions due to cost. Instead, ACR strongly supports patients having access to the right treatment and any necessary reference products at the right time.

“As the agency begins to explore changes and improvements to MA, ACR stands by as a resource to help ensure that enrollees with rheumatic diseases have better access to the quality care they deserve,” concluded Dr. Downey.