CMS Releases Final Medicare Advantage Call Letter

June 13, 2019

On April 1, 2019, the Centers for Medicare & Medicaid Services (CMS) released the final Medicare Advantage (MA) Call Letter for FY2020. The letter outlines policy updates and requirements for MA, Part D, and Medicare-Medicaid plan sponsors for the upcoming year. AAPM&R submitted comments on the draft call letter on March 1, 2019, and CMS addressed certain issues raised in our comments while remaining silent on some others.

In our comments, we urged CMS to ensure that coverage of non-opioid pain management benefits not restrict access to opioid-based services when medically necessary. CMS acknowledged these comments and agreed that “medically-necessary opioid therapy is appropriate when other options are not available.” Additionally, we asked CMS to adopt a uniform definition under MA plans for determining which chronic conditions would qualify individuals to receive supplemental benefits (e.g., ramp construction at one’s residence to enable the beneficiary to live independently). In response, CMS stated that they will apply the list of conditions that currently applies to MA coordinated care plans for special needs individuals, which can be found in the Medicare Managed Care Manual, chapter 16b.

CMS did not substantively address our comments on including rehabilitation access measures in the Star Rating program, the improper use of proprietary IRF admission guidelines rather than Medicare criteria, or our request that MA plans disclose which network IRFs are available to patients at discharge from an acute care hospital. CMS also did not meaningfully address the benefit category of “rehabilitative and habilitative services and devices” in this year’s letter.