Families USA Submits Comments on CMS 2025 Skip to Main Content

Families USA Submits Comments on CMS 2025 Medicare Advantage and Part D Advance Notice for Changes to Medicare Advantage Payment Policies


Families USA submitted comments on the Advance Notice of Methodological Changes for Calendar Year (CY) 2025 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies (i.e., 2025 Advance Rate Notice).  

As Medicare Advantage plans now provide health care coverage to more than half of all Medicare beneficiaries, it is critical that policymakers ensure the MA program is providing access to high-quality, affordable, and equitable care that Medicare beneficiaries deserve and can count on. 

However, too often MA organizations and plans engage in harmful business practices that negatively impact Medicare beneficiaries and U.S. taxpayers alike. These practices include deceptive marketing schemes to prospective enrollees, and systematic upcoding of services, and more; all of which drive overpayments, undermine healthy competition within the program and puts at risk our ability to hold the MA program accountable.  

Families USA applauds much of what CMS has done so far to rein in the corporate abuses in MA, including select proposals in this rate notice — however we urge CMS to do more to hold MA plans accountable, particularly around systematic upcoding and overpayments.  

Included within the comments are recommendations for changes to the 2025 Rate Announcement such as:  

  • Apply a higher coding adjustment factor above the minimum requirement to fully account for intensive coding by MA plans, targeting plans which engage in upcoding.  
  • Exclude information collected exclusively through in-home risk assessments (HRAs), which are easily abused and contribute to upcoding.  
  • Use two years of Medicare and MA diagnostic data to avoid diagnoses due to errors or inappropriate coding from another year.  
  • Initiate longer-term reforms of, or explore alternatives to, the CMS-HCC Risk Adjustment Model to institute a health care system that promotes health equity delivers patient-centered care. 

As enrollment in MA plans continues to climb, Families USA stands ready to work to ensure our nation’s seniors and all who rely on Medicare for their health care are protected and have the high-quality care and coverage options they deserve. 

Click the download button to view the Comment.