CMS continues its efforts to increase data transparency and data capabilities in Medicare Advantage by issuing a Request for Information 

According to the Centers for Medicare & Medicaid Services (CMS), the Medicare Advantage program has now exceeded 50% of Medicare enrollments and in order to further increase transparency and strengthen programmatic data, on January 25, 2024, the agency issued a Request for Information (RFI) seeking wide-ranging input from the public. 

While Medicare itself is a government program, Medicare Advantage is a “type of Medicare Health Plan offered by a private company that contracts with Medicare,” and plans may, “offer some extra benefits that Original Medicare doesn’t cover” according to Medicare.gov.  

REASON FOR RFI 

With such involvement by private health plans and the growth of the Medicare Advantage insurance market, in the statement announcing its RFI, CMS noted the need to “ensure that MA plans appropriately use taxpayer funds,” especially given that it expects that the government will pay health plans over $7 trillion over the next decade. It is also seeking information that will help ensure healthy competition in the marketplace.  

CMS is also placing a strong emphasis on the needs of Medicare Advantage enrollees (and potential enrollees) referred to as beneficiaries, including care quality and outcomes. It has stated that a “lack of transparency in Medicare Advantage managed care plans deprives patients of important information that helps them to make informed decisions,” and attempts to address anticompetitive and anti-consumer practices can also be said the be a part of this focus.  

In terms of programmatic data, CMS stated that their goal is ultimately, “to have, and make publicly available, MA data commensurate with data available for Traditional Medicare to advance transparency across the Medicare program, and to allow for analysis in the context of other health programs like accountable care organizations, the Marketplace, Medicaid managed care, [and] integrated delivery systems, among others.” 

SCOPE AND EMPHASIS OF RFI 

Through the RFI, CMS is inviting interested parties to provide feedback and recommendations on “all aspects of data related to the MA program.” This includes data CMS has been collecting as well as data that is not currently being collected.  

They have also requested that academic researchers and other data analysts provide “precise detail and definitions on data format, fields, and content that would facilitate comprehensive analyses of any publicly released MA data.  

CMS specifies that they are especially interested in the following: 

  • Data-related recommendations related to beneficiary access to care including provider directories; 
  • Prior authorization and utilization management, including denials of care and beneficiary experience with appeals processes; 
  • Cost and utilization of different supplemental benefits; 
  • All aspects of MA marketing and consumer decision-making; 
  • Care quality and outcomes; 
  • Healthy competition in the market; including the impact of mergers and acquisitions, high levels of enrollment concentration, and the effects of vertical integration; and 
  • Special populations such as individuals dually eligible for Medicare and Medicaid, individuals with end stage renal disease (ESRD), and other enrollees with complex conditions.  

The RFI states that comments must be received by May 29, 2024. 



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