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Apr 28 -- The Centers for Medicare & Medicaid Services (CMS) invites comments to OMB by May 31, 2023 regarding the Implementation of the Medicare Prescription Drug Plan (PDP) and Medicare Advantage (MA) Plan Disenrollment Reasons Survey. [Comments due 30 days after submission to OMB on May 1.]

The Balanced Budget Act of 1997 required that the CMS publicly report two years of disenrollment rates on all Medicare + Choice (M+C) organizations. Disenrollment rates are a useful measure of beneficiary dissatisfaction with a plan; this information is even more useful when reasons for disenrollment are provided to consumers, insurers, and other stakeholders. Advocacy organizations agree that CMS needs to report disenrollment reasons so that disenrollment rates can be interpreted correctly.

Specifically, the MMA under Sec. 1860D–4 (Information to Facilitate Enrollment) requires CMS to conduct consumer satisfaction surveys regarding the PDP and MA contracts pursuant to section 1860D–4(d). Plan disenrollment is generally believed to be a broad indicator of beneficiary dissatisfaction with some aspect of plan services, such as access to care, customer service, cost of the plan, services, benefits provided, or quality of care.

The information generated from the disenrollment survey supports CMS' ongoing efforts to assess plan performance and provide oversight to the functioning of Medicare Advantage (Part C) and PDP (Part D) plans, which provide health care services to millions of Medicare beneficiaries (i.e., 28 million for Part C coverage and 49 million for Part D coverage).

Beneficiary experiences of care (as measured in the MCAHPS survey) and dissatisfaction (as measured in the disenrollment survey) with plan performance are both important sources of information for plan monitoring and oversight. The disenrollment survey assesses different aspects of dissatisfaction (i.e., reasons why beneficiaries voluntarily left a plan), which can identify problems with plan operations; performance areas evaluated include access to care, customer service, cost, coverage, benefits provided, and quality of care. Understanding how well plans perform on these dimensions of care and service helps CMS understand whether beneficiaries are satisfied with the care they are receiving from contracted plans. When and if plans are found to be performing poorly against an array of performance measures, including beneficiary disenrollment, CMS may take corrective action.
 
The Medicare Advantage and Prescription Drug Plan Disenrollment Reasons Survey captures the reasons Medicare beneficiaries voluntarily disenroll from their Medicare Advantage (MA) health and prescription drug plan (PDP) contracts.  The Disenrollment Reasons Survey provides additional insight about reasons people leave their MA and PDP contracts beyond what disenrollment rates tell us.  The survey excludes beneficiaries who involuntarily disenrolled from contracts for eligibility reasons, moved out of their contract’s service area, died, are Low Income Subsidy (LIS) beneficiaries reassigned by CMS, and those who switch from one plan benefit package to another under the same contract.  Since 2013, CMS has surveyed beneficiaries who have voluntarily disenrolled from PDP and MA contracts.

The PDP and MA Plan Disenrollment Reasons Survey is administered using three survey versions tailored to the type of contract the beneficiary left:  1) a stand-alone prescription drug plan (PDP) version; 2) a Medicare Advantage Prescription Drug (MA-PD) plan version; and 3) a Medicare Advantage (MA)-only version.  A random sample of voluntary disenrollees from each contract is drawn monthly and surveyed as soon as possible following the beneficiary’s actual date of disenrollment.  The sampled participants receive a pre-notification letter and up to two mailed survey packages (original and follow-up) within a 1-2 month window from time of disenrollment.  The survey asks participants what reasons prompted them to disenroll from their contract including financial, drug or health benefits, customer service, and the coverage of doctors and hospitals by the contract.

Public reporting and policy relevance: Survey results are grouped into composite measures, so that the reasons given by disenrollees can be compared across contracts. Five composite measures are available: “Financial Reasons for Disenrollment,” “Problems with Prescription Drug Benefits and Coverage,” “Problems Getting Information and Help from the Plan,” “Problems Getting the Plan to Provide and Pay for Needed Care” and “Problems with Coverage of Doctors and Hospitals.”

MA/PDP Disenrollment Reasons Survey: https://www.cms.gov/Research-Statistics-Data-and-Systems/Research/CAHPS/MAPDP_DisenrollmentSurvey
CMS submission to OMB: https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202304-0938-020 Click IC List for information collection instrument, View Supporting Statement for technical documentation. Submit comments through this webpage.
FRN: https://www.federalregister.gov/d/2023-09053

For AEA members wishing to submit comments, "A Primer on How to Respond to Calls for Comment on Federal Data Collections" is available at https://www.aeaweb.org/content/file?id=5806

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