Radar on Medicare Advantage

InnovAge Stock Falls as Regulators Scrutinize PACE Operations

Despite better-than-expected financial results posted for its fiscal-year 2022 second quarter, shares of InnovAge — the largest provider of Programs of All-Inclusive Care for the Elderly (PACE) — tumbled last week amid concerns about its ability to grow in the face of intensifying regulatory scrutiny. Between federal audits and issues with its state partners, InnovAge’s many struggles relate to program compliance and may demonstrate the difficulties of scaling up a specialized care model in a highly regulated industry.

Providing services primarily through a dedicated center, PACE organizations support frail, elderly Americans who require a nursing-home level of care by offering comprehensive medical care and social supports to help them remain at home. The PACE market serves about 51,000 participants, most of whom are dually eligible for Medicare and Medicaid, and it is largely composed of regional organizations. As the dominant PACE organization, InnovAge serves 12% of that market.

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CMS Seeks to Level Member Playing Field Via Stars Changes

Aside from a headline-grabbing estimated pay boost of nearly 8% for Medicare Advantage organizations next year, the Biden administration’s first preliminary rate notice didn’t include many surprises for MA and Part D sponsors. Instead, the notice focused largely on potential changes to star ratings in the name of advancing health equity and monitoring member experience. At the same time, the notice addressed one aspect of payments for insurers serving a large portion of patients diagnosed with end-stage renal disease (ESRD) but left another to future policymaking.

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2022 Outlook: Increased Marketing Oversight Is Top MAO Compliance Concern

While CMS guidance and oversight regarding Medicare Advantage sales and marketing was rather uneventful under the Trump administration, several recent actions by the Biden administration signal a growing focus on Medicare marketing, including MA organizations’ use of third-party entities. The most notable of those was an October 2021 memorandum that explicitly reminded MAOs that they are responsible for the activities of first tier, downstream or related entities (FDRs), including third-party marketers with which they may not directly contract. CMS in that memo clarified that MA plans must submit all marketing materials to CMS prior to use, even when certain advertisements do not mention a plan by name, and reiterated this in its latest update to the Medicare Communications and Marketing Guidelines.

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Infographic: Out-of-Pocket Prescription Drug Costs Remain a Burden for Medicare Beneficiaries

Most older adults in the U.S. have been diagnosed with one or more chronic illnesses, and managing these conditions presents a significant cost burden, according to a January study in JAMA Internal Medicine. The authors studied eight of the most common chronic conditions, both as single disease states and in clusters, and determined hypothetical annual out-of-pocket (OOP) costs for individual seniors enrolled in Medicare Advantage-Prescription Drug plans and Standalone Part D plans in 2009 and 2019. While annual costs for many of the conditions dropped, likely due to the availability of new generic drugs, OOP costs for atrial fibrillation, type 2 diabetes and heart failure skyrocketed. This was attributed to the introduction of brand-name therapies without generic alternatives that received clinical guideline recommendations. To remedy this, study authors urged Congress to act on drug pricing reforms, including allowing Medicare to negotiate list prices and cap annual OOP costs for seniors.

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News Briefs: America’s Physician Groups and Others Are Urging CMS Not to Cancel GPDC Model

America’s Physician Groups (APG) and other stakeholders at press time were urging the Biden administration not to cancel the Global and Professional Direct Contracting (GPDC) model. The model, in which provider groups and other entities share risk and receive capitated payments for serving fee-for-service (FFS) Medicare beneficiaries, formally launched in April 2021 and has drawn interest from Medicare Advantage organizations. Although CMS put a pause on new applicants for the 2022 performance year, progressive lawmakers have asked the administration to stop it out of concern that private entities are seeking to funnel FFS enrollees into managed care without their knowing. In a sign-on letter to HHS Secretary Xavier Becerra, APG and other groups suggested that instead of canceling the model, the administration should limit participation to provider-led entities and “place additional guardrails and add more beneficiary protections.”

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Humana Seeks to Calm Investors With EPS Outlook, $1B Value Plan

As publicly traded Medicare Advantage insurers begin to report fourth-quarter and full-year 2021 earnings, Humana Inc.’s recent disclosure of lower-than-expected individual MA growth for 2022 has raised questions among the investment community around the use of external sales channels and their impact on membership churn. But reports by UnitedHealth Group and Anthem, Inc. in late January seemed to assure investors that Humana’s experience was not reflective of an overall trend, while executives during Humana’s Feb. 2 earnings call vowed that the MA-focused insurer is making every effort to ensure its external partners appropriately convey what members are buying and confirmed its long-term growth outlook.

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Potential 5-Star SEP Disruption Depends on Marketing Prowess

With 74 Medicare Advantage Prescription Drug plan contracts earning a 5-star rating for 2022, compared with just 21 such plans last year, an unprecedented number of MA-PD plans have the ability to market 5-star products throughout the year — thanks in large part to COVID-related adjustments to the star ratings that are not likely to reoccur. According to multiple industry experts, that anomaly presents a unique set of challenges for plans that weren’t expecting to be 5 stars and could create some unusual midyear enrollment shifts.

That all depends, however, on how aggressive 5-star plans are with their marketing and how many enrollees take advantage of the so-called 5-star special enrollment period (SEP). While MA insurers have the advantage of marketing their 5-star plans year round, enrollees who are in a service area where a 5-star plan is available may switch from their current Medicare plan to a 5-star contract one time between Dec. 8 and Nov. 30.

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CMS Rule Proposes to Take Dual Integration to the Next Level

In its new rule proposing an array of policy and technical changes for the 2023 Medicare Advantage and Part D contract year, CMS devoted a large section to advancing integration of Medicare and Medicaid benefits for dually eligible individuals. Though the rule is largely in line with the goals of the SNP Alliance, whose member plans serve approximately 2.5 million Special Needs Plan (SNP) enrollees, the organization says many of the proposals will require greater collaboration between states and plans, as well as more specificity and standardization around the proposed collection of social determinants of health (SDOH) data.

The proposed rule, Medicare Program; Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs (87 Fed. Reg. 1842, Jan. 12, 2022), included the following provisions:

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Star Ratings Surge Could Disrupt the Market During Special Enrollment Period

The pandemic-fueled boom in 5-star rated Medicare Advantage contracts could cause “significant market disruption” in 2022, suggests a new report from Wakely. In an analysis of enrollment data from CMS, the actuarial consulting firm found that 5-star contracts account for 19% to 30% of MA intra-year enrollment growth (i.e., enrollment gains occurring between February and December of a particular year), with 5-star contracts growing between 3.8% and 5.1% midyear. Since 5-star plans have the advantage of marketing their products all year long and enrolling members who qualify for the 5-star special enrollment period, the major increase in the number of available 5-star plans has the potential to create unprecedented enrollment shifts later this year. The report warned, however, that midyear plan switchers may have a less-than-favorable risk profile.

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On Higher FFS Costs, MA Risk Scores, CMS Proposes Pay Boost of 8% for 2023

In addition to floating a variety of potential changes aimed at advancing health equity in the Medicare Advantage and Part D programs, CMS in its Feb. 2 release of the 2023 preliminary rate notice estimated that MA plans will see an average pay boost of 8% in 2023. And that estimate could change: CMS for 2022 originally estimated that plans would receive an average reimbursement increase of 2.8%, then bumped that estimate up to 4.08% in the final rate announcement.

To Evercore ISI, the 2023 estimate isn’t far off from the “all-in” rate increase of 7.6% in 2022, when considering average risk coding trend, which varies by company.

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