U.S. Chamber Signs 2025 MA Advance Notice Coalition Letter

March11, 2024

TheHonorableChiquitaBrooks-LaSure Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
200IndependenceAvenue,SW,Room445-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 seniorsandpeoplewithdisabilitieswhochooseMedicareAdvantage.Asadiversegroupofstakeholders, we want to recognizethe CentersforMedicare&MedicaidServices (CMS) focuson improving Medicare Advantage for beneficiaries and the opportunity to engage in the public comment period.

MedicareAdvantagecurrentlyserves51percentoftheMedicarepopulation,whichisexpected to increasein2024asenrollmentisprojectedtoreachnearly34millionbeneficiaries.MedicareAdvantage also covers an increasingly diverse population, with the largest increases in enrollment among historicallyunderservedpopulations,includingBlack,Latino,AsianAmerican,NativeHawaiian,Pacific Islander, dual eligible, and low-income beneficiaries.

AsweassesstheimpactoftheCY2025MedicareAdvantageAdvanceNotice,weareconcernedthatthe current proposal does not fully account for the sharp increase in seniors’ utilization of health care services,inpartduetothesignificantincreaseinuseofhealthcareservicesthatisoccurring following theCOVID-19pandemic.Nearlyone-quarterofMedicarebeneficiariesreporteddelayingcareduringthe 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 growthtrendsthanCMS’s estimates.

Forthesereasons,webelieveCMSshouldincorporatemorerecentandcompletedatawhenfinalizing the Rate Notice. Thisdata should reflectcurrentutilization andcost trends to promotestability in the Medicare Advantage program and continued progress in advancing health equity, preventing disease progression, and delivering high-value, high-quality care.

TheBRGanalysisindicatestheimpactthesechangescouldhaveonbeneficiariesifthefinalRateNotice does not account for increased health care utilization.On average, beneficiaries may experience a $33 reductioninhealthcarevaluepermonth,andmorecomplexpopulationslikedualeligiblesmay 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 benefitscouldmeanalossofdental,hearing,andvisioncoverage, reducedaccesstotelehealthbenefits, decreased allowances to helpbeneficiariesaffordover-the-counter products, reduced behavioralhealth services, diminished transportation benefits to health care appointments, fewer nutrition-related servicesorpreparedmealsafterahospitalornursingfacilitystay,anddecreasedaccesstophysical 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,theMedicareAdvantageprogramcontinuestoadjustto significant policy changes implemented in recent years, including the phase-in of a new risk model, additionalchangestothewaytheprogramisadministeredandfunded,alongwithreformssupportedby BMA such as modernizing the prior authorization process and ensuring accuracy and transparency in marketingforbeneficiaries.Theremaybevariabilityinhowbeneficiariesandstakeholdersareimpacted by these ongoing changes as well; For example, special needs plans (SNPs) serve very high concentrationsofhighneed,medicallycomplexindividuals,makingstabilityparticularly imperative becauseofthevulnerablepopulationserved.Furtherchangesriskdisruptingseniors'accesstocare,and we are concerned the Advance Notice does not align with the goals³ we share with CMS to promote strengthandstabilityinMedicare Advantage.

Weappreciate CMSworkingwithallstakeholdersto assesstheimpactstheseproposalswillhaveon beneficiaries,especiallyvulnerablepopulations,whoseneedsarebestservedbythecomprehensive, coordinatedcaredeliveredinMedicareAdvantage.WelookforwardtocontinuedpartnershipwithCMS, other policymakers, and stakeholders to ensure that all Medicare beneficiaries receive equitable, high- quality, and affordable health care.

Sincerely,

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