Tag Archives: MACRA

As 2020 approaches, are Medicare Supplement carriers prepared for MACRA?

In September 2016, I published a white paper, “Will the Medicare Supplement market have “2020” vision in the world of MACRA?” Much was unknown at the time regarding formal regulatory guidance on the topic, including carrier and industry responses to the regulation. Much is still unknown about the impact of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) on Medicare Supplement carriers: will carriers take action proactively, or wait and react as we move into the 2020s?

There appears to be a general willingness (though not an endorsement) from the National Association of Insurance Commissioners’ Health Actuarial Task Force (NAIC HATF) to allow separate Plan G forms. That apparent willingness is based on the interpretation of “Guarantee Issue” availability as a separate “case” as described in current regulation. Supporters of this position argue that allowing separate Plan G forms protects pre-MACRA Plan G policyholders from the increased overall morbidity level expected for business sold after 2019. Some, though not all, regulators and industry groups share this stance, and the topic remains subject to continued debate. It is likely that the regulatory stance will vary by state.

However, what is not addressed is whether the same flexibility would be allowed for Plan F. If such flexibility is permitted, this would enable carriers to introduce more favorable rates in anticipation of more favorable experience.

The impact of MACRA will vary by carrier based on factors such as rate structure, level of underwriting, sales demographics, and in-force exposure. Carriers should take the key considerations below into account when evaluating their product lines:

Current sales distribution of enrollment type
Enrollment type would be Open Enrollees (OE), Guarantee Issue-eligible (GI), or medically underwritten (UW). All else being equal, a high proportion of OE and/or GI business and the shift of that business from Plan F to Plan G may also be expected to cause a shift in morbidity level from Plan F to Plan Gi. A high proportion of UW business may impact morbidity to a much greater extent for Plan F than Plan G. The extent of this impact depends on the strength of the underwriting process.

Rate structure
A rate structure with a relatively steep age slopeii will have a greater impact on experience (positive for Plan F and negative for Plan G) than a rate slope closer to the underlying claims slope. Why? All else being equal, a steep rate slope will likely have inherent subsidization of the younger ages by the older ages. Under MACRA, we may expect Plan F to take on a larger proportion of the subsidizers (older ages) while Plan G may be expected to assume a larger proportion of the “subsidizees” (younger ages).

Current volume of Plan G in-force
To the extent that a carrier will have a significant volume of Plan G enrollees by 2020, the initial impact of MACRA on Plan G enrollment for such carriers may be lessened. However, the same phenomenon would apply to Plan F but in the other direction.

Rate competitiveness
Rate competitiveness relative to industry competitors will play a key role in the volume and distribution of new business. But regardless of carrier decisions, it’s always prudent to analyze and quantify the potential impact of deviations.

Obviously, the future of Plan G is secure—or as secure as the entire Medicare Supplement market can be. I will close with commentary on the issue of the future of Plan F. Yes, Plan F will be restricted after 2019, but the potential market, while declining over time, won’t just disappear right away. Yes, it is likely that future Plan F sales will be to older individuals, but overall perhaps they will be healthier as a result of underwriting requirements. And yes, over time Plan F will become an older block and headed toward becoming effectively closed. However, keep in mind that older doesn’t necessarily mean less profitable, if age rating and past performance of pre-standardized plans are any indication.

iMACRA impacts Plans C and D in the same way but, for purposes of this blog, we limit reference to Plans F and G.
ii“Relative” to the underlying claims slope.

Medicare Shared Savings Program 2016 Track 3 financial results

Under the Medicare Access and CHIP Reauthorization Act of 2015, healthcare providers that participate in a Medicare Shared Savings Program (MSSP) as Track 3 accountable care organizations may qualify for the advanced Alternative Payment Model 5% bonus. Track 3 was first offered in 2016. This paper by Milliman consultants discusses first-year MSSP Track 3 performance and possible drivers of success.

Developing alternative payment models under MACRA

Alternative payment models (APMs) have become a popular way to tie payment to quality of care. The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) created incentives for providers to participate in APMs. This paper by Daniel Muldoon and Pamela Pelizzari explores key clinical and financial considerations that need to be addressed in a robust APM proposal.

Exploring the nuances of MACRA

The major terms and conditions of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) are becoming more well-known during the first performance year, but some aspects of the new physician payment system law still can be elusive for physician practices and other healthcare organizations. In this article, Milliman’s Pamela Pelizzari discusses details that may be overlooked regarding participation in the Merit-based Incentive Payment System track and the advanced alternative payment model track of MACRA.

This article was published by the Healthcare Financial Management Association.

MACRA considerations for Medicare Advantage plans

The Medicare Access and CHIP Reauthorization Act (MACRA) makes significant changes to the Medicare payment system by introducing a quality-based payment model. While MACRA primarily affects Part B clinicians, there are numerous implications that Medicare Advantage (MA) plans should consider. A strategic approach can help MA plans understand and respond to the legislation.

In the article “MACRA and Medicare Advantage plans: Synergies and potential opportunities,” Milliman actuaries explore the answers to the following questions:

• How will MACRA affect MA plans’ provider payments?
• What synergies exist between MACRA’s quality scoring and the MA Stars quality program?
• How can MA plans help providers achieve Qualifying Participant (QP) status?
• What incentives exist under MACRA for providers to improve risk score coding?
• How are MA plans in the market responding to MACRA?

Read Milliman’s “MACRA: The series” to learn how the legislation will affect providers, alternative payment models, and health plans

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 2020s.

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 2020s, 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?