Proposed Rule Summary - Medicare Advantage 2025 Proposed Rule

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Proposed Rule Summary - Medicare Advantage 2025 Proposed Rule


The proposed rule is a detailed outline of all changes/provisions that CMS proposes to make to the Medicare Advantage program in 2025 and beyond. These provisions are included into the proposed rule and open for public comment. Once the comment period is closed, CMS reviews those comments and compiles a Final Rule, which is typically published in spring the following year.

  • Proposals that have a direct impact on Outcomes include:

    • Moving MTM Completion Rate for CMRs to display page for no less than 2 years when/if MTM program expansion is finalized.

    • Social Needs Screening.

  • Other Notes

    • The proposed rule is out earlier this year than prior years (typically released in January or February. The FY24 Proposed Rule was released in December)
    • Comments back to CMS are due no later than 5PM ET on January 5, 2024
    • Full Text Available Here: 

Key Provisions 


Q: What is included? 

CMS is proposing the same adjustment to MTMP eligibility that was included into the CY24 Proposed rule last December, but also proposing to move the CMR completion rate measure to display for 2 years (since the denominator increase will be a substantive change). 


Q: Remind me again, what adjustments were proposed to MTMP eligibility? 

  1. Requiring plan sponsors to target all core chronic diseases identified by CMS, codifying the current 9 core chronic diseases-145 in regulation, and adding HIV/AIDS for a total of 10 core chronic diseases.
  2. Lowering the maximum number of covered Part D drugs a sponsor may require from 8 to 5 drugs and requiring sponsors to include all Part D maintenance drugs in their targeting criteria.
  3. Revising the methodology for calculating the cost threshold ($4,935 in 2023) to be commensurate with the average annual cost of 5 generic drugs ($1,004 in 2020). 


Q: How much would the MTM Program Eligibility change if the previously proposed criteria change happens? 

CMS estimated that the proposed changes would increase the number and percentage of Part D enrollees eligible for MTM from 4.5 million (9 percent) to 11.4 million (23 percent). 


Q: What are the specifics of the CMR completion rate measure change? 

If the changes to eligibility for the MTM program in the December 2022 proposed rule (described above) are finalized in a future rule, in this proposed rule CMS proposes to move the MTM Program Completion Rate for CMR Star Rating measure to a display measure for at least 2 years due to substantive measure updates. 



Beginning in Measurement Year 2023, Part C contracts are beginning to report additional measures that are a part of the Universal Foundation as a part of the display page. One of those measures is the new Social Needs Screening and Intervention measure that aligns with our SDOH service offering. CMS intends to submit these for consideration to the Star Ratings program in the future.  


Have questions? Let us help you navigate these changes ahead of time. 


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