CMS’s Early Release of Advance Notice Cements RAPS Phaseout

In a surprise move aimed at giving some clarity to Medicare Advantage and Part D plans already thinking about their 2022 plan bids, CMS on Sept. 14 released Part 1 of the 2022 Advance Notice. But the items in the notice were largely expected — including the final phaseout of legacy Risk Adjustment Processing System (RAPS) data in determining risk scores — and key information is still forthcoming.

CMS since 2018 has issued the Advance Notice of Methodological Changes for MA Capitation Rates and Part D Payment Policies in two parts, thanks to a requirement in the 21st Century Cures Act (signed into law in 2016) that any proposed changes to the CMS Hierarchical Condition Category (HCC) risk adjustment model have a 60-day comment period. The agency for 2021 posted the first document in January of this year (RMA 1/16/20, p. 1) and for 2020 issued it in late December.

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