LeadingAge offered its support and input to the Centers for Medicare and Medicaid Services (CMS) on its proposed data collection regarding Medicare Advantage (MA) plan initial service determinations and appeals (CMS-10905) in a comment letter submitted October 8.

CMS’ goals for this data collection effort are to provide key information on “the utilization of benefits, enhance audit activities to ensure plans are operating in accordance with CMS guidelines, and ensure appropriate access to covered services and benefits.”

LeadingAge has been pushing for CMS to have MA plans report prior authorization data for these exact purposes. Under the proposed data collection, MA plans would be expected to report quarterly to CMS on a series of data elements related to initial service determinations and appeals.

In our comments, LeadingAge encouraged CMS to expand the required data to include not only initial prior authorizations or other service determinations but also data on concurrent reviews and re-authorizations in order to provide a full picture of an MA enrollee’s health care journey and where the barriers to access exist.

LeadingAge also offered additional suggestions on data elements that required further clarification or that would enhance efforts to achieve CMS’s goals for the data.

Finally, we recommended that CMS disseminate the data through an annual report and consider publishing some of the data in Medicare plan finder as well as incorporating key metrics in the MA Star Rating program in the future.

The proposal does not specify which year plans will be required to start submitting these data though we do know it would begin on January 1 . To review the complete LeadingAge comment letter, click here.