In our November 12 comments to the Center for Medicare and Medicaid Services’ (CMS) Medicare Part C Utilization Management Annual Data Submission and Audit Protocol Data Request (CMS-10913), LeadingAge told the agency we are grateful for the opportunity to offer our support for and also provide further input into the agency’s Medicare Advantage plan-related data collection work.  Our comments offer feedback about how CMS’ efforts could be improved.

The proposal outlines a list of items that all plans will be required to report to CMS on internal coverage criteria (ICC) and a more comprehensive set of information that select plans would be required to submit as part of an audit of ICC.  LeadingAge supports this effort to ensure these ICC are only being used limitedly and when appropriate to determine access to Medicare services. It is not clear when this new data collection effort will be initiated but we encouraged CMS to implement beginning January 1, 2025. To read our full comment letter, click here.