On January 25, 2024, CMS released a Request for Information (RFI) seeking public input on how it can enhance and increase transparency of Medicare Advantage (MA) data. CMS says that the RFI “builds on our existing MA data transparency efforts to further align with Traditional Medicare and provide the data we need to ensure the growing Medicare Advantage program best meets the needs of enrollees.” The agency has invited comments from all interested parties, including MA plans, providers, and academic researchers. Comments to the RFI are due 120 days after the date it is published in the Federal Register, which is currently scheduled to occur on January 30, 2024.

This RFI was spurred by feedback CMS received from a previous RFI. On August 1, 2022, CMS solicited comments on how best to improve the MA program. Commenters to that RFI said that CMS should collect and publish more MA program data, including data about supplemental benefit cost and utilization, value-based payment arrangements between providers and plans, utilization management and prior authorization, claim denials and appeals, network adequacy, market competition, etc. The calls for greater transparency of MA data were echoed by OIG, the Government Accountability Office, and MedPAC.

The RFI published last week requests comments on all data related to the MA program, including both data that is and is not currently collected. CMS is particularly interested in hearing about “common challenges and experiences in the MA program for which limited data are currently available.” The agency says that the information solicited by the RFI will support efforts to ensure that there is healthy competition in the market for MA plans and that MA plans are meeting the needs of beneficiaries and appropriately using taxpayer funds.

CMS is specifically soliciting comments on data-related recommendations concerning beneficiary access to care, including provider directories and networks; prior authorization and utilization management, including denials of care and the appeals process; cost and utilization of supplemental benefits; MA marketing and consumer decision-making; care quality and outcomes; MA plan market competition; and special populations of MA beneficiaries such as individuals eligible for Medicare and Medicaid and ESRD patients.

For each data-related recommendation, CMS requests that commentors explain the rationale, goals and questions that could be addressed with newly released data, and how such data could support new action or CMS regulations.

The RFI encourages MA plans, providers, and data vendors to comment on the operational considerations of collecting additional MA data. CMS is also seeking comments on how it can improve how MA data is collected and released to the public.

The RFI is available here, and a CMS press release about the RFI is available here.