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Additional perspectives on Robert Berenson's article 
are available by clicking on the author's name below:

Joseph AntosJohn BertkoRon Klar • Murray Ross •
Patricia Salber and Bruce Bradley
H E A L T H A F F A I R S : P E R S P E C T I V E
W E B E X C L U S I V E
28 N O V E M B E R 2001 Paying Medicare+Choice Plans:
The View From MedPac

What do we do when efficient plans' costs diverge from what Medicare would have spent in the traditional program?

by Murray N. Ross


Before the Balanced Budget Act (BBA) of 1997, Medicare's payments to managed care plans were linked to fee-for-service (FFS) costs per beneficiary in individual counties. Wide variation in FFS costs across counties meant that managed care payment rates also varied widely. To address a perceived inequity–in which Medicare beneficiaries in some (mostly urban) areas had access to plans offering much greater benefits than those available to beneficiaries in other (mostly rural) areas–Congress changed how Medicare pays such plans when it created Medicare+Choice (M+C). It put a floor under payments, provided for blending of local and national payment rates, and limited increases in payments to higher-paid areas. Last year Congress raised the floor further.

Taken together, these steps have reduced the variation in M+C payment rates across the country. Reducing variation in payment rates, however, has introduced a different problem by creating the potential for Medicare's payments to plans in some market areas to diverge greatly from FFS costs in those markets. In counties where payment rates have been raised above FFS costs, Medicare may pay M+C plans more to provide the basic benefit package than it would have spent otherwise, thus increasing program spending. In other counties payments to M+C plans may fall below FFS costs as updates are limited. <%-1>Over time, plans paid less than FFS costs will have difficulty in contracting with providers if their payments do not allow them to compete with payment rates in the traditional FFS program.

MedPAC's proposal.
The Medicare Payment Advisory Commission (MedPAC) believes that Medicare's payment policies should not steer beneficiaries to either M+C plans or the traditional FFS program. Moreover, the commission recognizes that one cannot fight the market: No matter how much payments to plans are manipulated, achieving parity in payments to M+C plans across markets while maintaining parity between M+C and traditional Medicare within local markets cannot be accomplished as long as there is so much underlying variation in FFS spending across market areas. Therefore, MedPAC recommended in its March 2001 report that payments for beneficiaries in the two sectors of a local market be made equal, taking into account differences in beneficiaries' health status (risk).1

The commission recognized that its recommendation would not ensure choice for all beneficiaries, because the characteristics of some markets are simply not conducive to managed care. In many rural areas, for example, plans have little negotiating power because there are few hospitals and physicians; the absence of managed care plans in such areas is not unique to Medicare. But MedPAC's recommendation would permit choice in areas where it is viable without raising spending. This contrasts with current policy, which discourages managed care plans from participating in areas where they have been able to bring additional value to Medicare beneficiaries and raises payments in areas where they cannot. Moreover, by raising payments above FFS costs in some areas, current policy increases spending with no assurance that the extra payments yield additional benefits to beneficiaries.

Berenson's counterproposal. Robert Berenson takes issue with the MedPAC recommendation, arguing that the linkage between spending for M+C plans and traditional Medicare should be removed rather than reinforced. He proposes instead that in the absence of a comprehensive restructuring of the Medicare program, M+C plans should be viewed as simply another type of provider, with payment updates based on their own characteristics and performance. Berenson's proposal would in essence set M+C payments at what it costs efficient plans to provide the basic benefit package, with appropriate adjustments for factors such as risk that are beyond plans' control.

The logical consistency of such an approach is appealing; Berenson would have Medicare treat a person-month of care the same way it treats a hospital stay or an office visit. But his approach raises both policy and operational questions.

Policy analysis. The key policy question is what to do when efficient plans' costs diverge from what Medicare would have spent in the traditional program. In cases where plans' costs exceed FFS–as is likely to be the case in rural areas–it is hard to argue that Medicare should pay more for the same benefit. Indeed, this is exactly what Medicare now confronts in a number of floor counties: The program pays a higher rate to a private FFS plan for the same unmanaged care that the traditional program delivers.

But what if plans provide additional benefits or higher quality? With respect to additional benefits, why have Medicare only pay for them selectively through M+C rather than programwide? Paying plans more because they provide higher quality is certainly worth considering, but as Berenson himself points out, we are a long way from overcoming the technical and administrative barriers to doing so.

If plans in higher-cost areas can deliver the basic benefit package less expensively than can the traditional program, who should benefit? Because participation in M+C is voluntary for plans and providers, and because Medicare beneficiaries have no incentive to leave the traditional program unless they get something in return, the answer surely must be that these parties should share in any efficiency gains. Were Medicare to seek budgetary savings, participation in M+C by plans, providers, and beneficiaries would decline, as we have seen in many areas in the post-BBA period.

Some observers might argue that because M+C plans decide whether to enter markets on the basis of their own costs, not on local FFS spending, paying them less than FFS costs will not necessarily have negative consequences. But this argument ignores the fact that the providers with which plans contract do compare payment rates to FFS. Moreover, attempting to determine plans' costs to support reducing payments below FFS suggests requiring plans to file some type of analogue to the hospital cost report. The question is then whether instituting a costly and potentially unreliable mechanism to allocate insurers' costs to individual products and markets for the purpose of calculating payment rates would generate enough savings to make it preferable to using readily available data on FFS spending. Such an approach does not appear promising.

This brings us full circle: We do not want to overpay M+C plans, and we cannot underpay them, or they (and beneficiaries) will not participate. Whether or not we treat M+C plans as just another type of provider, the appropriate benchmark for payments is local FFS spending, adjusted for risk.

Crucial first step. Berenson concludes that instead of viewing private health plans as a vehicle to reduce costs or provide additional benefits, we might better focus on how to reward plans that improve quality and help manage care for Medicare beneficiaries with chronic diseases. He notes that doing so would require a new regulatory and payment structure and new authority for the Centers for Medicare and Medicaid Services (CMS) to select better-performing plans. These steps would face numerous barriers. MedPAC has not addressed the notion of value-based purchasing in M+C, but the commission has repeatedly endorsed a crucial first step: development of a risk-adjustment system that can appropriately reward plans that care for sick beneficiaries. Until such a system is implemented, plans that develop a reputation for caring for beneficiaries with serious or chronic illnesses will be punished financially because their payments do not reflect the higher costs of such enrollees.

The author thanks Glenn M. Hackbarth, MedPAC chair, for his helpful comments.

NOTE

1. Medicare Payment Advisory Commission, Report to the Congress: Medicare Payment Policy (Washington: MedPAC, March 2001).

Murray Ross is executive director of the Medicare Payment Advisory Commission (MedPAC), an independent legislative agency that advises Congress on Medicare policy issues.

2001 Project HOPE–The People-to-People Health Foundation, Inc.