NCQA Responds to CMS’s CY 2025 Medicare Advantage Policy and Technical Changes Proposed Rule

NCQA commends CMS on their proposals to improve access to behavioral health and supplemental benefits and incorporate health equity components into plans’ utilization management operations. NCQA encourages CMS to finalize select D-SNP proposals and embed digital quality measures into quality ratings and payment programs.

January 5, 2024

Chiquita Brooks-LaSure, Administrator
Centers for Medicare & Medicaid Services
Department of Health & Human Services
Hubert H. Humphrey Building
200 Independence Ave. SW
Washington, DC 20201

Attention: CMS–4205–P

Dear Administrator Brooks-LaSure:

The National Committee for Quality Assurance (NCQA) thanks you for the opportunity to provide feedback on the CMS Contract Year 2025 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs Proposed Rule.

NCQA is a private, 501(c)(3) not-for-profit, independent organization dedicated to improving health care quality through our Accreditation and measurement programs. We are a national leader in quality oversight and a pioneer in quality measurement. Leveraging our strengths as a trusted third party, we are committed to helping organizations navigate the challenges associated with moving to an equitable health care system. Our mission to improve the quality of health for all Americans, with a focus on health equity and support for meaningful value-based payment models, propels our daily work.

We are pleased to provide comments in the following areas:

  • Expanding Behavioral Health Care. NCQA supports the proposals to increase behavioral access and transparency in Medicare Advantage by adding a new facility type for Outpatient Behavioral Health.
  • Evidence and Access to Supplemental Benefits. We agree Medicare Advantage plans should provide mid-year notification of available supplemental benefits to beneficiaries and have documented evidence for the clinical benefit of the offering.
  • Health Equity in UM operations. health equity components should be embedded into utilization management operations.
  • Dually Eligible Managed Care Services. CMS should finalize proposals to streamline requirements for D-SNPs and D-SNP look-alikes to promote integration and reduce harmful marketing practices.
  • Medicare Advantage Quality Reporting. We encourage CMS to advance policies to embed the Universal Foundation and digital quality measures into quality ratings and payment programs.

Improving Access to Behavioral Health Care

NCQA applauds CMS’s efforts to expand behavioral health services for Medicare beneficiaries, and we are encouraged by the proposal to introduce a new facility type for Outpatient Behavioral Health to Medicare Advantage network adequacy requirements. We believe the proposals are appropriate given the inclusion of marriage and family therapists and mental health counselors as qualified Medicare providers in 2024. This expansion of provider types in the Medicare program is a welcomed addition, and Medicare Advantage plans should expand their networks to include these outpatient behavioral health providers.

Strengthening Quality and Use of Supplemental Benefits

NCQA supports CMS’s proposals for Special Supplemental Benefits for the Chronically Ill. Supplemental benefits can play a role in addressing health disparities by providing services and supports that impact health-related-social-needs. Despite the increased number of benefits available to beneficiaries, documentation of impact and utilization of supplemental benefits is low. We agree that Medicare Advantage plans should be required to demonstrate – through relevant acceptable evidence – that supplemental benefits have a reasonable expectation of improving or maintaining enrollee health. To increase utilization of available benefits, we also support the requirement for plans to notify enrollees of the unused supplemental benefits at mid-year. These proposals will help advance the quality and uptake of supplemental benefits.

Like CMS, NCQA is committed to advancing health equity and improving health outcomes by addressing health-related-social-needs. In 2023, we introduced a Social Need Screening and Intervention (SNS-E) measure into the HEDIS performance measurement set, which assesses members who were screened for unmet food, housing and transportation needs, and who received a corresponding intervention if they screened positive. We recommend CMS incorporate the SNS-E measure into Medicare Advantage Star Ratings, as contemplated in last year’s Advance Notice.

We also encourage CMS to leverage accreditation programs in Medicare Advantage to advance health equity, the first pillar of CMS Strategic Plan. NCQA’s Health Equity Accreditation Plus program builds on Health Equity Accreditation and helps organizations integrate health and social care to address the social drivers of health. Accredited organizations must collect data on social needs and upstream social risks of the communities they serve and make data-driven decisions that improve members’ access to, and experience with, community-based partnerships and resources.

Incorporating Health Equity Analysis into Utilization Management Policies and Procedures

NCQA supports the proposals to explicitly incorporate health equity into the composition and responsibilities of the Utilization Management (UM) Committee for Medicare Advantage plans. Additional transparency and oversight of UM is critical to advancing accountability in a growing Medicare Advantage market. We agree it is important to specifically require health equity expertise on the UM Committee and plans should be required to conduct analyses of their UM policies for health equity implications. We also support requiring plans to conduct an annual analysis of prior authorization stratified by social risk factors.

NCQA remains committed to advancing health equity by assessing and identifying areas with unwarranted differences, amplifying the voices of underserved communities and promoting actions that reduce disparities and propel health care toward equity for all. We are honored the CMS Office of Minority Health (OMH) awarded NCQA a contract to help OMH integrate health equity into the development, evaluation and implementation of CMS policies, programs and partnerships. We look forward to our growing partnership to advance the health equity research and quality improvement.

Increasing the Percentage of Dually Eligible Managed Care Enrollees Who Receive Medicare and Medicaid Services from the Same Organization 

NCQA commends CMS’ efforts to support the enrollment of dually eligible beneficiaries into integrated models of care. We agree with CMS that contracting standards for D-SNP look-alikes should be consistent with the requirements for D-SNPs. Additionally, we believe it is appropriate to limit the number of D-SNPs a parent organization can offer within a state to promote integration and reduce harmful marketing practices. It is imperative that dual beneficiaries are enrolled in a plan with access to benefits that meet their level of care needs. Limiting plan enrollment to just dually eligible enrollees would enable performance measurement and Accreditation options that are specific to this population.

The proposed rule also suggests state agencies use their State Medicaid Agency Contract (SMAC) to align policy state policy priorities for integrating and aligning D-SNP and Medicaid benefits. NCQA advises states on how to advance quality outcomes by aligning accreditation requirements in SMACs. We welcome the opportunity to help CMS promote Accreditation as a tool to bring greater accountability and transparency for Dual beneficiaries. For instance, ACL’s Strategic Framework for Action: State Opportunities to Integrate Services and Improve Outcomes for Older Adults and People with Disabilities encourages states use NCQA’s LTSS Accreditation programs to meet care coordination requirements for Medicare-Medicaid integration.

Universal Foundation Measures in the Star Ratings Program

NCQA applauds the adoption of the Universal Foundation measures in Medicare Advantage Star Ratings and the effort to align measures across CMS programs. The Universal Foundation is crucial in supporting the industry’s move to digital quality measures (dQMs). We are proud that 70% of the measures in the Universal Foundation are HEDIS measures, all of which are currently specified as dQMs. We are excited to see alignment between CMS’s efforts and our work to promote high-quality, equitable care by moving to next-generation digital measurement and measuring what matters across the continuum of care. We are eager to continue our work together to reach our shared goals.

Thank you for the opportunity to comment. We remain committed to working with CMS to build a more equitable, sustainable and responsible American health care system. We welcome a discussion on our experience and recommendations to continue to strengthen Medicare Advantage. If you have any questions, please contact Eric Musser, Assistant Vice President of Federal Affairs, at (202) 955-3590 or at


Margaret E. O’Kane

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