2021 Advance Notice Elevates EDS Use, Leaves Out ESRD

The biggest news out of CMS’s Jan. 6 release of Part I of the 2021 Advance Notice may be that there was no news. As expected, CMS proposed continuing to phase out risk score data based on diagnoses contained in the legacy Risk Adjustment Processing System (RAPS) and increasing the use of encounter data that still vexes some Medicare Advantage organizations. But the document left out any mention of possible payment revisions for the expected influx of MA enrollees with end-stage renal disease (ESRD) next year, raising the question of when (and how) CMS might address a payment structure that is seen as inadequate by some industry stakeholders.

This is the third year CMS is publishing the Advance Notice of Methodological Changes for MA Capitation Rates and Part D Payment Policies in two parts, thanks to the 21st Century Cures Act (signed into law in 2016) requiring that any proposed changes to the CMS Hierarchical Condition Category (HCC) risk adjustment model have a 60-day comment period.

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