LeadingAge submitted comments on the CY 2025 Medicare Advantage (MA) proposed policy and technical rule on January 5. The proposals are markedly different from last year, primarily requiring more transparency and actions from MA plans and fewer changes with direct impacts on providers.

Nonetheless, the proposed rule presents opportunities to push for greater oversight of MA plans. In this vein, LeadingAge offered its support to CMS in collecting more data on plan activities such as prior authorizations, care denials, and appeals; providing a facility-based institutional special needs plans exception to network adequacy requirements in certain circumstances; removing barriers for beneficiaries who want to appeal a plan’s denial or discontinuation of care to an independent review entity; and creating additional opportunities for dual eligibles to enroll in integrated dual eligible special needs plans (D-SNPs).

As long-time proponents of integrated services, especially for dual eligibles, LeadingAge supports proposals that would create more opportunities for dual eligibles to enroll in an integrated D-SNP—but we also argue that CMS should further refine these proposals to allow dual eligibles to elect a PACE program and not just an integrated D-SNP during newly-proposed special enrollment periods.

We also raised a concern that certain aspects of these D-SNP proposals might lead to further market consolidation and the impact such consolidation is having on our members in the form of inadequate provider payments under MA coupled with increased administrative burdens. We encouraged CMS to examine these proposals closely to ensure certain safeguards against such consolidation.

We closed the letter by noting areas not addressed by the rule that still need attention as CMS continues its efforts to improve the MA program for its 31 million plus enrollees, including: provider payment adequacy and administrative burden; developing a formal process like a provider complaint line where they can submit instances of plan non-compliance related to coverage determinations and other issues; and opportunities to further improve the MA appeals process.