The mechanics of risk adjustment and incentives for coding intensity in Medicare

Author:

Carlin Caroline S.1ORCID,Feldman Roger2,Jung Jeah3ORCID

Affiliation:

1. Department of Family Medicine and Community Health, School of Medicine University of Minnesota Minneapolis Minnesota USA

2. Division of Health Policy and Management, School of Public Health University of Minnesota Minneapolis Minnesota USA

3. Department of Health Administration and Policy College of Public Health, George Mason University Fairfax Virginia USA

Abstract

AbstractObjectiveTo study diagnosis coding intensity across Medicare programs, and to examine the impacts of changes in the risk model adopted by the Centers for Medicare and Medicaid Services (CMS) for 2024.Data Sources and Study SettingClaims and encounter data from the CMS data warehouse for Traditional Medicare (TM) beneficiaries and Medicare Advantage (MA) enrollees.Study DesignWe created cohorts of MA enrollees, TM beneficiaries attributed to Accountable Care Organizations (ACOs), and TM non‐ACO beneficiaries. Using the 2019 Hierarchical Condition Category (HCC) software from CMS, we computed HCC prevalence and scores from base records, then computed incremental prevalence and scores from health risk assessments (HRA) and chart review (CR) records.Data Collection/Extraction MethodsWe used CMS's 2019 random 20% sample of individuals and their 2018 diagnosis history, retaining those with 12 months of Parts A/B/D coverage in 2018.Principal FindingsMeasured health risks for MA and TM ACO individuals were comparable in base records for propensity‐score matched cohorts, while TM non‐ACO beneficiaries had lower risk. Incremental health risk due to diagnoses in HRA records increased across coverage cohorts in line with incentives to maximize risk scores: +0.9% for TM non‐ACO, +1.2% for TM ACO, and + 3.6% for MA. Including HRA and CR records, the MA risk scores increased by 9.8% in the matched cohort. We identify the HCC groups with the greatest sensitivity to these sources of coding intensity among MA enrollees, comparing those groups to the new model's areas of targeted change.ConclusionsConsistent with previous literature, we find increased health risk in MA associated with HRA and CR records. We also demonstrate the meaningful impacts of HRAs on health risk measurement for TM coverage cohorts. CMS's model changes have the potential to reduce coding intensity, but they do not target the full scope of hierarchies sensitive to coding intensity.

Funder

National Institutes of Health

Publisher

Wiley

Reference14 articles.

1. Centers for Medicare and Medicaid Services. Risk Adjustment. n.d. Accessed May 31 2022.https://www.cms.gov/Medicare/Health-Plans/MedicareAdvtgSpecRateStats/Risk-Adjustors

2. Center for Medicare and Medicaid Services.2019 Software and ICD‐10 Mappings.2019Accessed February 1 2022.https://www.cms.gov/Medicare/Health‐Plans/MedicareAdvtgSpecRateStats/Risk‐Adjustors‐Items/RiskModel2019

3. Centers for Medicare and Medicaid Services.Advance Notice of Methodological Changes for Calendar Year (CY) 2024 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies.2023Accessed February 13 2023.https://www.cms.gov/files/document/2024-advance-notice.pdf

4. Centers for Medicare and Medicaid Services. Fact Sheet: 2024.Medicare Advantage and Part D Rate Announcement.2023.

5. Medicare Advantage Chart Reviews Are Associated With Billions in Additional Payments for Some Plans

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