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  • Writer's pictureNerieth Moreno-Santana

MMAPA Letter To CMS Underscores Need To Break Spiral To The Bottom, Address Inequities For Medicare

Medicare Advantage (MA) rates present a perfect opportunity for CMS to act on inequities in federal programs ahead of the 2023 MA rates announcement on April 4th; MA rates in Puerto Rico have dropped to 41% below the U.S. average since passage of the Affordable Care Act


March 18, 2022

WASHINGTON, D.C. — Today, the Medicaid and Medicare Advantage Products Association of Puerto Rico (MMAPA) announced its Advance Notice of Methodological Changes for CY 2023 letter to the Centers for Medicare & Medicaid Services (CMS). The letter highlights how the gap in Medicare Advantage (MA) funding between Puerto Rico and the mainland has been growing for 13 years and provides steps to remedy the inadequate treatment.


MMAPA states that CMS has the legal authority to establish a minimum standard average geographic adjustment for MA rates, closing the gap and allowing plans to meet the extensive socioeconomic and health care needs of their beneficiaries. Puerto Rico's historic struggle with poverty has been compounded over the last five years by natural disasters and the pandemic. Over 90% of eligible Medicare beneficiaries in Puerto Rico and 98% of beneficiaries that are dually eligible to Medicare and Medicaid enroll in Medicare Advantage. Leaving the MA funding disparity as-is exacerbates disparities and relegates the health care system in Puerto Rico to second-tier status. Given the program's popularity, the magnitude of the distance to the bottom is harmful to the health care of all citizens residing on the island.


MMAPA President Roberto Pando Cintrón issued the following statement in support of the letter:


“Notwithstanding enrollment trends or the extent of supplemental benefits available through Puerto Rico MA plans, something is wrong if the benchmarking system locks Puerto Rico into ever-declining funding within the MA program. We are not aware of any argument that Congress intended MA rates to steadily fall further behind national rates over time, nor are we aware of a rationale as to why CMS’ current benchmarking methodology steadily depresses MA rates for Puerto Rico.”


"The health care needs of Puerto Rico’s patient and provider populations are significant. The MA program has already been the foundation of Puerto Rico’s health care system in the past 15 years. It serves over 630,000 citizens and is the most regulated and operationally mature managed care program in Puerto Rico with the federal government having direct monitoring and compliance processes over the private managed care organizations. Many providers and physician specialists are able to offer care in Puerto Rico because MA plans reimburse at higher rates than commercial insurance or Medicaid. Mitigating disparities with fixes that establish more equitable MA rates would allow for increased provider payments to further reverse the flight of providers to the states.”


The MA program in Puerto Rico has proven to be a platform that can do more with less, with documented improvements in quality based on health plan start rating scores. Moreover, MMAPA's proposals would still leave Puerto Rico benchmarks lower than any state, but they would at least equate the funding level per beneficiary to the levels already in place for beneficiaries residing in the neighboring territory of the U.S. Virgin Islands (USVI). Puerto Rico rates are currently 23% below those of the USVI.


You can read the full letter detailing the gap in funding, historical context, and the path forward that MMAPA proposes to remove inequities and establish the proper treatment of American citizens in Puerto Rico. The letter to CMS is signed by MMAPA President Roberto Pando Cintrón and the executive board.

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