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C-TAC Submits MA Call Notice Comments

C-TAC submitted comments to CMS this week on their 2019 Medicare Advantage (MA) and Part D draft call letter. Several areas were of great importance to those living with advanced illness. We were supportive of the following:

  • Risk adjustment model – We recommended that two additional diagnoses be considered: Dementia with complications and Dementia without complications. We also encouraged CMS to include social determinants of health diagnosis codes in the risk model as Medicare beneficiaries with the same health condition can have different health costs due to their education, income, or neighborhoods.
  • New Measures for 2019 Star Ratings – We supported the addition of the new measures “Statin Use in Persons with Diabetes” and “Statin Therapy for Patients with Cardiovascular Disease,” but pointed out that these may eventually become counterproductive for those with advanced illness and that this population should be excluded from those measures. In addition, we reiterated that there are not yet appropriate measures that capture patient outcomes, care experiences, or alignment of care with personal goals and values for the advanced illness population. 
  • Health-Related Supplemental Benefits – We strongly supported the revised interpretation of supplemental benefits as this will allow funding for nutrition, transportation and other typically non-medical benefts. These are the kind of benefits that are more pertinent to those with advanced illness than traditional medical ones.

However, C-TAC voiced significant concerns with many aspects of the proposed Part D Opioid Overutilization Policy that seek to identify people at risk for opioid abuse. Overall, while we understand that these policies seem a sensible approach to the current opioid abuse crisis for the general population, people with advanced illness other than cancer may often be taking opioids appropriately, even if at seemingly high doses or in combination with other potentiating medications. We noted our concern that any effort to reduce opioid abuse should not inadvertently reduce access to opioids for those who justifiably need them.  One solution we suggested was to exclude those with advanced illness, or who are receiving palliative care, from these provisions, as is the case for those with cancer or on hospice.

Read the full comments here.

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