loading…
loading…
loading…
82
published predictive ratios in the CY 2026 Advance Notice showing that the model tends to predict well for low-income beneficiaries across all deciles of risk, including in the highest deciles of predicted risk. Comment: A few commenters suggested that CMS examine modifying the underlying data and structure of the RxHCC model, such as incorporating prescription drug claims into the model to supplement medical diagnoses and incorporating concurrent data markers for drug conditions. Another commenter suggested that CMS incorporate patient-reported outcomes and social drivers of health into the RxHCC model, expressing a belief that these measures would better address the realities of underserved populations by offering insights into beneficiary experience. Response: CMS thanks the commenters for their suggestions but notes that these suggestions are outside the scope of the information presented in the CY 2026 Advance Notice. Comment: One commenter suggested that CMS include an RxHCC for chronic kidney disease stage 3 into the payment model as is done in the CMS-HCC model. The commenter believed that including this RxHCC would encourage Part D plans to promote early chronic kidney disease intervention. Response: CMS appreciates the comment. While we regularly review the RxHCC model for improvements, it is important to note that the RxHCC model specifically predicts plan costs for prescription drugs, not medical costs. As a result, payment RxHCCs may not always be identical to payment CMS-HCCs if the conditions are not strong predictors of both drug and medical costs, respectively. Comment: Several commenters expressed concern about the impact of the proposal in the CY 2026 MA and Part D proposed rule to cover anti-obesity medications on the RxHCC model. These commenters stated a belief that the proposed coverage of these medications would result in increases in expected utilization and costs that the model does not account for. The commenters requested that CMS update the model to account for these expected cost increases from beneficiary utilization. Response: CMS is not finalizing the proposal to expand coverage of anti-obesity medications in Part D, as noted in the final rule titled, Contract Year (CY) 2026 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly (CMS-4208-F). Comment: Some commenters asked that CMS allow for a 60-day comment period for the RxHCC model so that plans have more time to evaluate the methodological changes. Some of these commenters further asked CMS to collaborate more with stakeholders prior to the publication of the Advance Notice regarding model changes. Several commenters requested that CMS publish additional analyses or provide more data to stakeholders regarding model impacts prior to publication of the Advance Notice. Some of these commenters specifically mentioned