With an estimated pay boost just under 1% and the continued increase of encounter data used in determining Medicare Advantage plans’ risk scores, MA reimbursement in 2021 isn’t looking as robust as it has in recent years now that both parts of the Advance Notice have come out. Meanwhile, MA plans face new uncertainties as patients diagnosed with end-stage renal disease (ESRD) can begin enrolling in such plans on Jan. 1, 2021. And while some changes in Part II of the Advance Notice stand to lower rates for serving ESRD enrollees, CMS in a separate memo proposed a new methodology for setting maximum out-of-pocket (MOOP) cost limits that will partly account for ESRD costs starting in 2021.
CMS, in its Feb. 5 press release announcing Part II of the Advance Notice, said it would accept comments on all proposals contained in the notice through March 6, before publishing the final rate notice by April 6. But the agency did not include or mention the draft Call Letter, which it releases annually with a comment period and usually contains proposals for MA and Part D plans to consider before they submit bids in June. Instead it released a 900-page proposed rule outlining policy and technical changes for contract years 2021 and 2022, and a separate memo with bid and operational instructions for bids due June 1.