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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Lauren Flynn Kelly

Lauren Flynn Kelly Managing Editor, Radar on Medicare Advantage

Lauren has been covering health business issues since the early 2000s and specializes in in-depth reporting on Medicare Advantage, managed Medicaid and Medicare Part D. She also possesses a deep understanding of the complex world of pharmacy benefit management, having written AIS Health’s Radar on Drug Benefits from 2004 to 2005 and again from 2011 to 2016. In addition to her role as managing editor of Radar on Medicare Advantage, she oversees AIS Health’s publications and manages the health editorial staff. She graduated from Vassar College with a B.A. in English.

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