We deeply appreciate the work Congress and the Administration have done to stabilize the economy and the health care delivery system during the national health emergency coronavirus (COVID-19). These changes, including both financial assistance and modifications made to regulations, offer support for the health care system and will have a positive impact on people’s lives, as they seek to meet the health care needs of our nation at this time of crisis.
We write today, to advocate for policies that further strengthen Medicare Advantage as a high quality, cost effective choice for seniors and those with disabilities eligible for Medicare. Over the past weeks as plans and providers have made adjustments to coverage and care delivery for millions of beneficiaries, we continue to identify policy issues that require attention. We appreciate the many actions already taken to address key issues and wish to draw your attention to several issues that need attention.
Specifically, the provider organizations who serve Medicare Advantage beneficiaries have concerns stemming from unintended consequences that have resulted from the need to respond to the COVID19 emergency. Some provider organizations serve primarily Medicare Advantage beneficiaries, many have targeted high-risk beneficiaries in underserved communities, while others serve both Medicare Advantage beneficiaries and those covered by Traditional Medicare. All are experiencing major disruption in care delivery and reductions in expected revenue, as they implement new ways to care for their patients and maintain appropriate staffing levels. Financial relief for these providers is essential to ensure the continuity of care for patients and employment for their staff.
Many of the most prominent and innovative primary care groups in the nation are risk-bearing providers with strong track records of success serving Medicare Advantage patients. The flexibilities built into Medicare Advantage allow these practices to be nimble and adapt quickly to the shifting nature of COVID-19, such as moving more services and care to the appropriate site of care, expanding the use of telehealth, and enhancing supplemental services essential to home-bound seniors and those with disabilities.
Extending Relief to Medicare Advantage Providers
In response to the national emergency, Congress and the Administration have been working to keep as many people employed as much as possible, especially those who work in health care. The focus has, correctly, been to ensure care for those infected by COVID-19 and support the providers on the frontlines of this care. These providers, including those who serve Medicare Advantage beneficiaries, are preparing for, or are already caring for an increased workload due to COVID-19.
Medicare Advantage providers are very much on the frontline for their beneficiaries, often as the initial contact for their patients. They are actively working to ensure care is provided when necessary and deferred whenever possible. As a result, many of these providers are seeing a reduction in utilization and thus a significant reduction in claims submission and payments. This reduced utilization is leading to staff reductions and cash flow issues for many, if not all, providers who are not directly caring for large numbers of COVID-19 patients. With stay-at-home orders, they are experiencing between 30 percent to 75 percent reductions in patient volume.
To adequately respond to financial distress, we offer specific actions that would significantly help stabilize Medicare Advantage provider practices affected by COVID-19 and enhance their capacity to meet patient needs, maintain their workforce, and weather this crisis:
- Ensure that the Centers for Medicare and Medicaid (CMS) include Medicare Advantage beneficiaries in the calculation of patients with respect to providers who are given provider relief funding under the Coronavirus Aid, Relief, and Economic Security Act (CARES). We understand the first distribution was primarily for hospitals and only for care provided to Traditional Fee-For-Service Medicare beneficiaries, excluding Medicare Advantage beneficiaries in the calculation of beneficiaries cared for by these providers. Further distributions should include Medicare Advantage beneficiaries.
- Ensure that distressed providers serving Medicare Advantage beneficiaries are able to participate in Medicare’s financial assistance programs, such as the Accelerated Payments Program, if their financial circumstances warrant it. Stabilizing finances of these providers would go a long way to ensuring Medicare Advantage providers are able to continue to protect the health of their patients and can keep their staff employed.
- Extend business loans and grants, including the Paycheck Protection Program, to providers with over 500 employees that serve multiple locations. Many of the organizations mentioned above and others have multiple locations and many levels of staff. Making a specific extension of this financing program for health care providers will ensure that our delivery system stays strong and intact now and in the coming months when utilization returns.
Ensuring that these providers who care for over one-third of the Medicare beneficiaries have access to financial support during this crisis will enable them to provide care and services to beneficiaries and maintain and protect their workforce. As you take further action to meet the needs of America’s population impacted by COVID-19 and mitigate adverse consequences in the health care system, we ask that you give consideration and add language to include the innovative, value-based providers and accountable care organizations who are working tirelessly to meet the needs of millions of Medicare Advantage beneficiaries who rely on them for their health and well-being.
Thank you for your attention and consideration, and please reach out to BMA’s Chief of Staff, Robin Goracke, at email@example.com or (202) 253-7581 with any questions and comments.
American Medical Group Association
America’s Physician Groups
Better Medicare Alliance
Direct Primary Care Coalition
Healthcare Leadership Council
National Association of Accountable Care Organizations
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