As of May 2022, the Medicare Advantage (MA) program represents 46% of national enrollment in Medicare, a percentage that reflects rapid growth. Just five years ago, a third of Medicare beneficiaries were enrolled in MA; today, MA enrollment is nearing half of all Medicare enrollment.

And as this program grows, the Medicare population is getting older, leading to a higher prevalence of age-related chronic conditions and functional and cognitive impairments. On top of this, our internal analysis shows that Black and Latinx beneficiaries experience functional and cognitive impairments at significantly higher rates than white beneficiaries.[1] Not to be overlooked, it is critical that program design accommodates the need of younger Medicare beneficiaries with disabilities.

It’s within this context that CMS is assessing future directions for the MA program, issuing a recent Request for Information on the MA program. As CMS noted in the Federal Register, they are “seeking feedback on ways to strengthen Medicare Advantage in ways that align with the Vision for Medicare and the CMS Strategic Pillars”.

ATI has done significant work in MA over the last several years, notably on advancing person-centered supplemental benefits for beneficiaries with complex chronic conditions, integration of MA and Medicaid for dually-eligible populations, and support for post-acute care. Some of our research is highlighted in our data insights, shared shortly after the release of the RFI. Based on these insights and more, we took the opportunity to share our thoughts with CMS given the critical role that MA plays in the Medicare program as a locus of innovation and, increasingly, the payer of choice for enrollees.

In light of these trends, future MA policy must consider more deliberate opportunities to support person-centeredness, to recognize the outsized role that family caregivers play, and to integrate with Medicaid to promote equitable access and health outcomes. In order to accomplish these things, we believe CMS several key opportunities:

  • Improving data collection and offering greater transparency to researchers, states, and other stakeholders to assess how well non-medical benefits, value-based contracting, and other innovative approaches to care delivery are addressing Medicare beneficiary needs and to determine areas for improvement in post-acute care;
  • Providing greater accountability for plans to invest in community infrastructure that supports families and caregivers in navigating systems for healthcare, social, and other non-medical supports;
  • Reducing the burden on enrolled beneficiaries and their caregivers by streamlining and simplifying information around and access to plan choices, benefits, appeals processes, and other cumbersome practices; and
  • Better incorporating beneficiary and caregiver perspectives to ensure that primary navigators of care can help the agency (and plans) reduce the burden of navigating care

We look forward to working with CMS, providers, plans, beneficiaries, and caregivers, on ensuring that the MA program delivers accountable, person-focused, high-quality healthcare. Read our full response here.

[1] For example, ATI analysis of the 2019 Medicare Current Beneficiary Survey shows that, compared to white Medicare beneficiaries, Black and Latinx Medicare beneficiaries are 46% more likely to have 2 or more ADLs and 44% more likely to have cognitive impairment.

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