3 11 24 Coalition Better Medicare Alliance2025 Advance Notice CMS FINAL


March 11, 2024


March 11, 2024

The Honorable Chiquita Brooks-LaSure Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
200 Independence Avenue, SW, Room 445-G
Washington, DC 20201

Dear Administrator Brooks-LaSure:

Thank you for your ongoing leadership in protecting health care access for the more than 32 million seniors and people with disabilities who choose Medicare Advantage. As a diverse group of stakeholders, we want to recognize the Centers for Medicare & Medicaid Services (CMS) focus on improving Medicare Advantage for beneficiaries and the opportunity to engage in the public comment period.

Medicare Advantage currently serves 51 percent of the Medicare population, which is expected to increase in 2024 as enrollment is projected to reach nearly 34 million beneficiaries. Medicare Advantage also covers an increasingly diverse population, with the largest increases in enrollment among historically underserved populations, including Black, Latino, Asian American, Native Hawaiian, Pacific Islander, dual eligible, and low-income beneficiaries.

As we assess the impact of the CY 2025 Medicare Advantage Advance Notice, we are concerned that the current proposal does not fully account for the sharp increase in seniors’ utilization of health care services, in part due to the significant increase in use of health care services that is occurring following the COVID-19 pandemic. Nearly one-quarter of Medicare beneficiaries reported delaying care during the pandemic1, and many are now pursuing the care that they need. Current data backs up this trend. A range of external reports, including a recent analysis by Berkeley Research Group (BRG), cite higher growth trends than CMS’s estimates.

For these reasons, we believe CMS should incorporate more recent and complete data when finalizing the Rate Notice. This data should reflect current utilization and cost trends to promote stability in the Medicare Advantage program and continued progress in advancing health equity, preventing disease progression, and delivering high-value, high-quality care.

The BRG analysis indicates the impact these changes could have on beneficiaries if the final Rate Notice does not account for increased health care utilization. On average, beneficiaries may experience a $33 reduction in health care value per month, and more complex populations like dual eligibles may experience a higher reduction of $50 per month, on average2.

We must protect the high-quality health care that Medicare Advantage beneficiaries rely on, which includes low premiums and a robust range of supplemental benefits. Any changes that jeopardize these benefits could mean a loss of dental, hearing, and vision coverage, reduced access to telehealth benefits, decreased allowances to help beneficiaries afford over-the-counter products, reduced behavioral health services, diminished transportation benefits to health care appointments, fewer nutrition-related services or prepared meals after a hospital or nursing facility stay, and decreased access to physical fitness and wellness services. Beneficiaries have come to rely on these benefits, and losing them, coupled with increased health care costs, is a burden many of these seniors cannot afford.

We urge CMS to promote the stability of Medicare Advantage by finalizing rates that reflect the higher utilization trends being publicly reported and ensure any proposed changes in the final Rate Notice protect and strengthen the program. Moreover, the Medicare Advantage program continues to adjust to significant policy changes implemented in recent years, including the phase-in of a new risk model, additional changes to the way the program is administered and funded, along with reforms supported by BMA such as modernizing the prior authorization process and ensuring accuracy and transparency in marketing for beneficiaries. There may be variability in how beneficiaries and stakeholders are impacted by these ongoing changes as well; For example, special needs plans (SNPs) serve very high concentrations of high need, medically complex individuals, making stability particularly imperative because of the vulnerable population served. Further changes risk disrupting seniors' access to care, and we are concerned the Advance Notice does not align with the goals3 we share with CMS to promote strength and stability in Medicare Advantage.

We appreciate CMS working with all stakeholders to assess the impacts these proposals will have on beneficiaries, especially vulnerable populations, whose needs are best served by the comprehensive, coordinated care delivered in Medicare Advantage. We look forward to continued partnership with CMS, other policymakers, and stakeholders to ensure that all Medicare beneficiaries receive equitable, high- quality, and affordable health care.


1How Has Healthcare Utilization Changed Since the Pandemic? - Health System Tracker

2MA Advance Notice Does Not Offset Rising Medical Costs and Could Lead to Reduced Healthcare Value forBeneficiaries - Berkeley Research Group

3Strengthening Medicare Advantage for Beneficiaries: Recommendations for Policymakers - Better MedicareAlliance

3 11 24 Coalition Better Medicare Alliance2025 Advance Notice CMS FINAL