MGMA responds to CMS RFI on Medicare Advantage data (May 29, 2024)

May 29, 2024 

The Honorable Xavier Becerra
Secretary
Department of Health and Human Services
200 Independence Ave, SW
Washington, DC 20201

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS–4207–NC
P.O. Box 8013
Baltimore, MD 21244–8013

RE: Medicare Program; Request for Information (RFI) on Medicare Advantage (MA) Data

Dear Secretary Becerra and Administrator Brooks-LaSure:

On behalf of our member medical group practices, the Medical Group Management Association (MGMA) is pleased to submit comments in response to the Medicare Program; Request for Information on Medicare Advantage Data, published in the Federal Register on Jan. 30, 2024.

With a membership of more than 60,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 medical group practices ranging from small private medical practices to large national health systems, representing more than 350,000 physicians. MGMA’s diverse membership uniquely situates us to offer the following feedback.

The Congressional Budget Office (CBO) projects that the share of all Medicare beneficiaries enrolled in MA will rise to 61% by 2032.1 As the number of MA beneficiaries continues to grow, it is imperative that the MA program ensures adequate and transparent coverage to patients, timely payment to medical groups, and remains a viable pathway for medical groups to participate in value-based payment arrangements. These priorities cannot be achieved without accurate and robust data on MA utilization management practices including prior authorization, onerous care denials, and value-based contracts.

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