loading…
loading…
loading…
34
Attachment III. Responses to Public Comments on Part C Payment Policy Section A. General Comments Comment: CMS received many comments in response to the CY 2026 Advance Notice, with some supporting the direction of the proposals in the Advance Notice and others expressing concerns about the impacts of the proposed updates. Commenters who supported the proposals in the Advance Notice believed that the policies would promote access to care, improve health outcomes, and reduce beneficiary costs. The commenters also expressed support for the policy proposals and updates in the Advance Notice because they believed they will advance coordinated care, reduce administrative burden, and ensure payment rates accurately reflect the cost of care. Many commenters expressed general support for MA and believed that MA provides better care at lower costs than fee-for-service and enables plans to offer supplemental benefits. A few of these commenters believed that MA is a more efficient use of government funds compared to fee-for-service. A commenter expressed support for MA as a facilitator of value-based care. Another commenter expressed support for MA as important for delivery system reform. Response: CMS appreciates commenters’ support. Comment: Many of the commenters who did not support the proposed changes included in the Advance Notice felt that payment updates they considered unfavorable in the previous two years have put financial pressure on plans, providers, and beneficiaries. Some commenters expressed concerns that the proposed payment update in the Advance Notice is insufficient to keep pace with utilization and costs. Most of the commenters who opposed Advance Notice policies expressed concern about the impact on beneficiary access, including fewer plan options, limited benefits, and higher out-of-pocket costs. A few commenters expressed concern that the policy proposals in the Advance Notice could decrease competition in the MA market. A commenter suggested that this decreased competition would disadvantage small, nonprofit, and community- based MA plans and organizations. Several commenters expressed general opposition to MA, expressing concern over wasteful government spending. A few of these commenters were concerned about MA fraud, upcoding, and impact to the Medicare Trust Funds. One of these commenters also expressed concern that MA plans use deceptive marketing schemes and aggressive and inappropriate care denials. A commenter emphasized the importance of encouraging broader stakeholder input in the Advance Notice. They suggested developing less technical and dense materials for community- based organizations and Medicare beneficiaries. These suggestions include publishing a plain language primer on MA payment and proposed changes and asking the public specific questions about access and quality issues to gather information about what is happening on the ground. A commenter requested that all key information be included in the Advance Notice document, rather than referencing to published supporting files and Fact Sheets and providing information