The Centers for Medicare & Medicaid Services (CMS) issued a Request for Information (RFI) on Medicare Advantage (MA) data on January 30, 2024. This RFI is a part of the Biden-Harris Administration's efforts to promote competition in health care, which includes increasing transparency in the MA insurance market and strengthening programmatic MA data. CMS plans to use the information solicited by the RFI to support efforts for MA plans to best meet the needs of people with Medicare, for people with Medicare to have timely access to care, to ensure that MA plans appropriately use taxpayer funds, and for the market to have healthy competition.
ASN addressed the following topics related to MA data in a letter submitted to CMS on May 29, 2024:
Missing data on transparency: Despite estimates of MA enrollment amongst Medicare's End-Stage Renal Disease (ESRD) beneficiaries exceeding 50%, exact data on enrollment from CMS have not been made available. In response to this issue, ASN urged CMS to collect and publish the annual number and percentage of ESRD enrollees who enrolled in an MA plan and the annual number and percentage of those who disenrolled.
Questions of transparency: ASN has raised in previous comment letters concern that MA plans do not provide the same level of transparency as the Medicare Fee-for-Service program, which has a strong history of providing quality data to researchers and policymakers alike. ASN urged CMS to require MA plans to provide the ESRD enrollee data similar to the data collected for Fee-for-Service beneficiaries.
Medicare Chronic Condition Special Needs Plan: Little is known about the impact of Medicare's Chronic Condition Special Needs Plan largely, in part, because MA data have not been made available to researchers and policymakers. ASN urged CMS to publish these data.
Network adequacy: MA network adequacy issues refer to the concerns regarding the sufficiency and accessibility of health care practitioners within the networks of MA plans. Network adequacy issues can have significant implications for patients with kidney failure who require specialized care and frequent access to health care services. Although CMS requires MA plans to submit data on their physician networks, much of these data remain undisclosed to researchers and the public.
Equity: ASN stressed that improving data collection and transparency on MA coverage and enrollees is essential for promoting health equity and ensuring that patients with kidney failure have equitable access to high-quality health care services.
Prior authorizations: Currently, MA insurers are not required to report prior authorization requests, denials, and appeals by types of service, for a specific plan within a contract, or reasons for authorization denials. ASN stressed that improving data collection and transparency regarding prior authorization in MA plans is crucial for ensuring patients with kidney failure receive prompt access to the care and treatments that they need to manage their condition effectively and maintain their health and quality of life.
ASN will provide future updates as policy is refined. To read ASN's full response to the RFI, please visit https://www.asn-online.org/policy/webdocs/05.29.24MedicareAdvantageDataRFI.pdf or the ASN website at www.asn-online.org/policy.
