On February 13, LeadingAge submitted comments on CMS’s proposed rule governing how Medicare Advantage (MA), Special Needs Plans, Part D and PACE programs will operate in CY2024. The LeadingAge comments can be found here.

While our comments cover a range of topics, as did the proposed rule, the majority hone in on members’ pain points, including coverage determinations for traditional Medicare services and prior authorizations. LeadingAge asked for enhanced enforcement in these areas including suggesting a Confidential Provider Complaint Line for MA and standardizing the prior authorization form for traditional Medicare benefits to ease providers’ administrative burden and speed beneficiary access to services.

While not directly addressed in the rule, LeadingAge also highlighted the importance of safe discharges and noted MA plans should share some accountability. PACE comments urged CMS to balance the imposition of additional regulatory burden with ongoing flexibility for providers, while keeping participant wishes at the center of service provision.