“Mega Reg” rule stresses actuarial soundness in the development of capitation rates

With its publication of the final Medicaid managed care rule (final rule), the Centers for Medicare and Medicaid Services underscored the importance of actuarial soundness in the capitation rate development process. In this paper, Milliman’s Brad Armstrong, Christopher Pettit, and Marlene Howard summarize the implications that the final rule has on the development of actuarially sound capitation rates and required supporting documentation. The authors also discuss action items for states and their actuaries along with some areas where the new rule may present challenges in the certification of the rates.

Encounter data submission consideration for Medicare Advantage organizations

The Centers for Medicare and Medicaid Services (CMS) is shifting to the Encounter Data System (EDS) as the sole basis for Medicare Advantage organizations’ (MAOs) risk scores. EDS data will have a substantial influence on risk scores and revenue as early as payment year (PY) 2016.

In this article, Milliman consultants offer perspective on several analyses MAOs should consider to prepare data submissions for CMS. The authors also discuss some challenges MAOs may face when verifying that the data submitted through the EDS are complete and accurate and that all appropriate diagnosis codes are being accepted for risk adjustment by CMS.

Here’s an excerpt:

To provide an effective review of an MAO’s diagnosis code submissions, the following analytics can be undertaken:

• Calculation of risk scores from each diagnosis source: RAPS, EDS, and source claims/ chart review data
• Plan-level and member-level comparisons of risk scores based on each diagnosis source
• Analysis of submission gaps
• Analysis of coding gaps

To perform the EDS submission review, a possible first step is to create a “plan report card,” which summarizes the risk scores under accepted RAPS and EDS submissions and the risk scores based on all diagnosis sources (claims and chart review data) after applying the MAO’s specific RAPS filtering logic and the EDS filtering logic released by CMS.

Figure 1 provides an example of a potential Plan Report Card for PY 2016 EDS submission review. In this example, there is a 4.1% gap between the EDS risk scores and the risk scores after the MAO applied the EDS filtering logic to the source claims data. Also, based on the CMS return data, the EDS risk scores are four points lower than the RAPS scores. This indicates that the EDS submissions may be incomplete and that there are diagnoses in the source claims data that the CMS filtering logic has rejected.


If submissions to CMS contain all necessary data elements to successfully pass the filtering logic, the risk scores based on RAPS and EDS return data should match the risk scores calculated from the source claims and chart review data. In addition, if the RAPS and EDS filtering logic are the same, the RAPS and EDS risk scores should also be the same. However, there can be gaps between what is submitted and accepted by CMS and the claims and chart review data because of:

• Incomplete data submissions (e.g., claims being inadvertently filtered out or dropped, missing chart review data)
• Inaccurate data submissions (e.g., the wrong medical codes, such as incorrect bill type, being used in the submissions)
• CMS system errors (e.g., failure to match diagnosis data with the correct member)
• Other potential process errors

Furthermore, comparison of the RAPS and EDS risk scores will indicate whether the MAO’s revenue is being adversely affected by the move from RAPS to EDS. A focused look at the MAO’s own coding practices as they compare to Medicare FFS coding standards and EDS filter criteria can identify the coding gaps that may drive lower risk scores under EDS.

How will MACRA affect the Medicare Supplement market?

Clark_L_KennethWhat does recently passed legislation referred to as MACRA (Medicare Access and CHIP Reauthorization Act of 2015 ) mean for the Medicare Supplement industry? While the impact on Medicare Supplement doesn’t occur until 2020, individual carriers are in a position now to plan a course to proactively mitigate risks or exploit opportunities.

The Medicare Supplement market will split into two distinct markets.

There will be those that are newly eligible for Medicare in 2020 and later (NE group) who don’t have access to Plans C/F and the non-newly eligible (NNE group) that will still have access to Plans C/F. Why is this important? While the NNE group will shrink over time, it will still comprise a significant segment of the market in the early 2020’s.

Overall loss ratio experience should be better for a few years following MACRA implementation.

How is this possible? Consider that for new business sold in the early 2020’s, the NNE group that purchases Plans C/F will no longer consist of 65-year-olds who qualify for open enrollment without medical underwriting. Plan C/F morbidity will improve while Plan D/G morbidity will increase. For as long as Plans C/F make up a significant volume (and keep in mind this is older individuals at the higher rate levels), the overall loss ratio levels should be lower all else being equal.

In spite of more favorable experience, however, retention dollars are expected to be lower for all years following MACRA implementation.

While overall loss ratio experience may improve, the amount of retention dollars (premium less claims) will be lower given an increased exposure to lower benefit Plan D/G coverage that doesn’t include the Part B deductible. The overall impact through 2025 is likely to be in the billions of dollars.

To learn more about how MACRA will impact the Medicare Supplement market, read my article “Will the Medicare Supplement market have “2020” vision in the world of MACRA?

Qualifying APM participant considerations

This paper by Milliman’s Charlie Mills, Pamela Pelizzari, and Christopher Kunkel explores the challenges and opportunities regarding participation in an Advanced Alternative Payment Model (APM) track under the Medicare Access and CHIP Reauthorization Act (MACRA). The authors also discuss why becoming Qualifying APM Participants (QPs) may be desirable to some providers as well as the risks they might encounter through the process.

Here is an excerpt from the article:

Opportunities associated with QP status

Financial opportunities

Despite the potential downsides to participating in Advanced APMs and seeing QP status, there are also potential financial benefits, including the following:

A lump-sum payment equal to 5% of their prior year’s payments for Part B covered professional services. QPs can become eligible for this lump-sum incentive payment for years 2019 through 2024. Overall, this is the primary financial opportunity for QPs.

Insulation from the potential downside of the MIPS adjustment. In general, MIPS is a budget-neutral (i.e., zero-sum) program, with a financial downside of 4% in 2019, growing to 9% in 2022. Because QPs and Partial QPs are excluded from MIPS, they are not exposed to MIPS’s downside and do not have to navigate the hundreds of quality and performance measures that make up MIPS.

Opportunities for shared savings from the Advanced APM. QPs will have the opportunity to share in gains (and will generally be required to share in losses) from the Advanced APMs they participate in.

Higher conversion factor increases starting in 2026. Starting in payment year 2026, QPs will receive a conversion factor increase of 0.75% compared with 0.25% for non-QPs. Over time, this could result in significantly higher payment rates for QPs versus non-QPs.

Clinical integration benefits

Several of the currently available Advanced APMs aim to align incentives across different types of providers. For example, ACOs encourage physicians and hospitals to work together to ensure beneficiaries receive appropriate care that can keep them healthy and out of hospitals. In many cases, however, individual physicians do not see the financial benefits of these programs without entering into what can be complex and time-consuming gainsharing arrangements. By providing a 5% lump-sum incentive payment to QPs, MACRA serves to create an even greater incentive for physicians to participate actively in Advanced APMs.

While other payer Advanced APMs do not contribute to QP threshold calculations until performance year 2019 (incentive payment year 2021), it’s possible that the increased engagement physicians have in Advanced APMs that is due to MACRA will have trickle-down effects on other lines of business and patient populations beyond Medicare fee-for-service. This could serve to improve the quality of care and reduce costs for patients covered by other payers.

A difficult time: MPL insurers navigate the future

Over the past 10 to 15 years, medical professional liability (MPL) insurers have been fortunate to have enjoyed profitability strong enough to take the edge off the necessity of a deep structural market change. But the time is coming when insurers will have to face the reality. How will MPL insurers compete in a shrinking market and what will their role be? Milliman consultants Richard Lord and Stephen Koca provide some perspective in their article “A difficult time: MPL insurers navigate the future.”

This article was published in the 2016 Third Quarter issue of Inside Medical Liability.

An early look at Medicare’s episode payment models

The Centers for Medicare and Medicaid Services (CMS) released a notice of proposed rulemaking on July 25, 2016, that includes three major areas of focus:

• The creation of three new Medicare Parts A and B episode payment models (EPMs) under section 1115A of the Social Security Act
• The creation of a new cardiac rehabilitation incentive payment model
• Modifications to the existing Comprehensive Care for Joint Replacement (CJR) model

In addition to these major areas of focus, CMS also addresses the potential future of Medicare bundled payment models, indicating its intention to continue a voluntary bundled payment model after the conclusion of Bundled Payments for Care Improvement (BPCI) initiative, designed to help providers meet the criteria to take advantage of an Advanced Alternative Payment Model (APM), and inviting input on potential future condition-specific episode payment models.

In this article, Milliman’s Pamela Pelizzari outlines the major provisions of the proposed rule and offers perspective on some possible implications for affected providers.