Dear Administrator Tavenner:
The undersigned organizations are writing to request that the Centers for Medicare & Medicaid
Services (CMS) increase patient protections in the Medicare Advantage (MA) plan offerings in
the forthcoming draft 2016 Call Letter. The 2015 Call Letter reflected a willingness by CMS to
make changes to requirements regarding adequate notice to patients about provider networks in
these plans and offer options for seniors who have had changes imposed upon them during the
benefit year. While we appreciate your attention to this matter, we believe that more must be
done to provide potential and existing enrollees with adequate information to make decisions
about MA plans.
Over the past two years, physicians throughout the country have been removed “without cause”
from MA plan networks during the benefit year, which needlessly disrupts patients’ care.
Allowing plans to lock seniors into a plan that meets their needs and then removing physicians
from their network, disrupting their care, should not be permitted. Further, numerous
studies1, 2, 3, 4 have indicated that network directories provided to patients when selecting a plan
inflate the number of physicians available to them through the plan, which is misleading to
seniors when they are trying to make an informed decision about their health care needs.
Therefore, in the 2016 Call Letter, we urge you to: (1) prevent no-cause terminations throughout
the plan year; and (2) ensure that physician network directories are accurate, up-to-date, and
provide the information that patients need to make informed choices during the annual open
enrollment period. Specifically, these network lists need to be heavily revised for accuracy and
be readily available to beneficiaries. This will allow MA enrollees to select a plan with a
physician network that meets their needs. It will also give MA enrollees security in knowing that
their physicians cannot be dropped from the network during the benefit year.
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