The Centers for Medicare and Medicaid Services (CMS) yesterday issued the Final CY 2010 Call Letter for the Medicare Advantage and Part D Programs. The Final Call Letter closely resembles the Revised Draft CY 2010 Call Letter issued by CMS on February 23, 2009.
The following are examples of key issues addressed in the Final Call Letter:
Medical Loss Ratio: Although CMS requested comments regarding whether, and if so how, CMS should calculate and disseminate information about Medicare Advantage Plans’ medical loss ratios, the agency has decided, “given this issue’s complexity,” to continue to evaluate methodologies for possible future implementation.
Compliance Programs, Self-Audits and Data Validation: CMS appears to have dropped its proposal that Medicare Advantage Organizations and Part D Plan Sponsors (Plan Sponsors) “conduct self audits and report the results to CMS.” Rather, CMS indicates that it “will produce a performance profile” of Plan Sponsors and “target organizations that demonstrate poor performance” in addition to selecting Plan Sponsors at random. The agency also “intend[s] to assess the effectiveness of [Plan Sponsors’] compliance programs, including the requirement for effective internal monitoring and auditing.” CMS has retained its proposal that Plan Sponsors validate data that will be submitted to CMS, although CMS will roll out the requirements in phases. A pilot program will be launched in CY 2009 to test the data validation specifications that will be implemented in CY 2010.
Reference-Based Pricing: As expected, CMS adopts its prohibition on Part D Plan Sponsors using the reference-based pricing utilization control mechanism in CY 2010.
Other topics addressed in the Final Call Letter include Part D Plan Sponsors’ medication therapy management programs, the mandatory contract between Dual Eligible Special Needs Plans and state Medicaid agencies, and the elimination of Medicare Advantage Plans with low enrollment or duplicative plan benefits.
The Final CY 2010 Call Letter can be found on CMS’s website at http://www.cms.hhs.gov/PrescriptionDrugCovContra/Downloads/2010CallLetter.pdf.