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Puerto Rico To Be Disproportionately Harmed By Proposed Changes In MA Advance Notice

New report from Milliman shows Puerto Rico will face a significantly higher MA payment reduction than the national average. MMAPA believes this reduction will hurt the most vulnerable and marginalized Americans on the island.

As the Administration prepares for the proposed changes in the 2024 Medicare Advantage (MA) Advance Notice, a new report from Milliman found that these risk adjustment model changes will significantly reduce payments to Medicare Advantage Organizations (MAO) in Puerto Rico. According to the report, the proposed changes to the current MA risk score model could lead to a 9.1% reduction in MA payments in Puerto Rico, marking a disproportionate decrease in funding compared to the national average reduction of 3.4%. MMAPA believes this reduction will hurt the most vulnerable and marginalized Americans on the island.

"To protect chronically ill and the dual eligible beneficiaries (Medicare & Medicaid) in Puerto Rico, the Administration must adjust and ensure that these changes aren't implemented. The proposed changes will cut funding for MA in Puerto Rico in 2024 by an estimated $800 million as medical costs rise, leading to a reduction in benefits for Americans that will exacerbate health inequities across the island and within the national context of the Medicare program. We are even more concerned that providers, hospitals, health insurers, labs, and others will struggle to treat a large share of the population that is older, sicker, and poorer than the rest of the country," said Roberto Pando Cintrón, President of the Medicaid and Medicare Advantage Products Association of Puerto Rico (MMAPA).

"This Administration has regularly expressed the goal of addressing health inequities, but unfortunately, if these changes go through, some of the most vulnerable Americans in our country will be harmed the most. We are hopeful that these policies with unique negative effects to citizens in Puerto Rico will be withdrawn by CMS until further study based on these principles."

At the request of MMAPA, Milliman published a white paper to examine the implications of the Administration's proposed risk score model adjustments on payments to MAOs. The paper uses historical data and research from CMS to analyze the changes' impact by Medicare plan and determine the high-level impacts of the changes for each plan type and region. The conclusions of Milliman’s report align with earlier preliminary assessments by other actuarial firms. Puerto Rico already has the lowest MA base rates and would be hit with the largest reductions if the proposed policies are implemented.

Today, 1 in 5 people in Puerto Rico are MA beneficiaries, making the island home to the largest share of MA beneficiaries across the states. Those who are dual eligible for Medicaid and MA are part of an integrated program called Medicare Platino and represent 46% of MA enrollees. These Americans often face social determinants of health that negatively impact their wellbeing, such as food insecurity, lack of transportation, and poor housing. If the proposed changes to the risk model are implemented, many providers and MA organizations expect to lose the funds necessary to provide essential health care benefits and services to low-income and chronically ill Americans on the island, particularly those with diagnoses for diabetes and congestive heart failure.

Puerto Rico’s exclusion from equitable funding and distinct statutory treatment has been a perennial issue, and the island continues to be omitted from important policy discussions despite promises from multiple successful presidential campaigns to make the issue a priority. Today, MA rates on the island are 41% below the national average and 23% below the neighboring Virgin Islands. MMAPA has previously called on the Administration to set fair rates for MA in Puerto Rico and end decades of inequity on the island, but the proposed changes to the Advance Notice signal more challenges to come as providers in Puerto Rico fight to secure equitable health care for patients across the island. Apart from withdrawing the risk score model changes, MMAPA also presented new data to support the establishment of a minimum MA base rate similar to the current MA payment level in the US Virgin Islands.



The Medicaid and Medicare Advantage Products Association of Puerto Rico (MMAPA) is a non-profit organization comprised of the leading Medicaid and Medicare Advantage organizations in Puerto Rico. Founded in 2009, MMAPA is dedicated to promoting policy solutions to solve Puerto Rico's healthcare challenges.

Follow MMAPA on Twitter at @mmapapr or visit our website,

Media Contact:

Brendan Conley

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