Attachment III. Responses to Public Comments on Part C Payment Policy

Section J. CMS-HCC Risk Adjustment Model for CY 2024

<aside> 💡 This section of Part C comments and responses are extracted from Rate Announcement Section J (page 65 to page 115). The responses mainly presented the legality and history of this model update.

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Comment 1:

Commenters stated their support for the proposed CY 2024 CMS-HCC model, stating it improves payment accuracy, program integrity and helps address excess payments to MA organizations that have negatively affected taxpayers and beneficiaries. Specific examples of support included the following comments:

• Updating the model with more recent underlying data will improve the accuracy of risk adjustment and payments to MA organizations;
• Updating the model to account for the transition from ICD-9 to ICD-10 provides more quality diagnostic information;
• Making changes to address variation in coding will decrease the impact of variability in MA coding compared to FFS.

Response 1:

We thank the commenters for their support. We agree that moving to the 2024 CMS-HCC model will improve payment accuracy to MA plans and that updating the risk adjustment model is an essential part of CMS’ duty to effectively run the MA program and be a steward of the Medicare program.

Comment 2:

Many commenters requested CMS phase in the updated 2024 model over multiple years.

Response 2: Phase in over 3 years