The Blog to Transform Advanced Care

Advancing Care through Innovation, Observation and Collaboration.

C-TAC submitted the following comments on the Medicare Advantage (MA) Advance Notice for CY 2021:


  • The proposed adjustments to frailty and functional status assessment as these are important issues for those with serious illness.
  • Excluding those receiving palliative care from HEDIS measures that may no longer be medically appropriate for this population.
  • Excluding those with sickle cell disease from several opioid measures and recommended also excluding those receiving palliative care from such measures.
  • Potential new measure concepts such as a Physical Functioning Activities of Daily Living change measure, a Diabetes Overtreatment measure for older or frail adults with type 2 diabetes measure, and a Home Health Services new measure concept assessing the quality of care coordination for MA beneficiaries requiring home health services.

Not supported

  • The potential Initial Opioid Prescribing (IOP) Measures because they do not exclude those with advanced illness who may appropriately need higher or longer initial doses of opioids. We also suggested that those receiving palliative care or hospice be excluded from such measures.

In addition, we suggested that CMS consider a new measure: Improving Transition of the Serious Ill Population to Hospice to include three essential metrics:

  1. Percent of MA enrollees that transition to hospice. 
  2. Median length of stay in hospice for MA enrollees that transition to hospice. 
  3. Percent of transitions to hospice that died in less than or equal to 7 days.

Share This

Leave a Comment