February 25, 2014
VIA ELECTRONIC SUBMISSION (www.regulations.gov)
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-4159-P
P.O. Box 8013
Baltimore, MD 21244-8013
Re: Comments in Response to CMS-4159-P: Medicare Program; Contract Year 2015 Policy and Technical Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Programs
Dear Sir or Madam:
The Business Roundtable is an association of chief executive officers of leading U.S. companies. Together, our member companies employ more than 16 million individuals and provide health care coverage to over 40 million American workers, retirees, and their families. Business Roundtable is invested in addressing health care costs that hamper essential economic growth. For that reason, Business Roundtable has been critically engaged on the issues of health care reform implementation and ensuring that the Medicare program remains solvent and delivers on the safety net promise that has been made to all generations of Americans.
As part of Business Roundtable’s ongoing work toward securing the future of Medicare, we have long supported the expanded use of private plan options, such as the Medicare Advantage and Part D programs. These programs harness the power of the private industry to deliver cost-efficient, high-quality care to our seniors, while protecting the long-term solvency of the Medicare program and the overall fiscal health of this country. They must be adequately financed and reasonably regulated in order to provide Medicare beneficiaries access to these models of care.
This letter provides comments in response to the proposed rule entitled Medicare Program; Contract Year 2015 Policy and Technical Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Programs, published on January 10, 2014. Among other things, the proposed rule would clarify various programs’ participation requirements applicable to Medicare Advantage (MA) plans and Part D Plan (PDP) sponsors. Business Roundtable is concerned that several of the provisions contained within the proposed rule undermine the intent of the program, which was to create a prescription drug benefit for Medicare beneficiaries through private sector innovation. These proposed new interpretations have the potential to interfere with the market-based competition that exists within Part D programs which could, in turn, jeopardize the savings and quality improvements that have largely been the hallmarks of these private plans. Specifically, Business Roundtable is concerned that the proposed rule will limit prescription drug plans’ ability to engage in competitive contracting and innovative plan designs that drive savings to seniors and the program at large. Other proposed regulatory changes will impose unnecessary regulatory requirements, restrict innovations in plan design, and limit competition in offering innovative benefit designs that help consumers and payers.
Together, Medicare, Medicaid, and Social Security consume more than 40% of today’s Federal budget and are projected to account for a full half of the budget by 2020. Private health-care options within Medicare encourage competition on quality and cost while reducing fraud and wasteful spending, thereby protecting the solvency and availability of these programs. The recent experience of competition-driven improvements in quality and efficiency under Medicare Part D strongly indicate there are significant potential savings and improvement in care available through the provision of choice to well-informed seniors. For these reasons, Business Roundtable has supported the Part D program from its inception and strongly encourages CMS to ensure that any future regulations maintain competition and existing freedoms to contract, be financed as a viable option to traditional fee-for-service, and support the development and implementation of innovative plan designs in both MA and Part D.
The Business Roundtable sincerely appreciates your consideration of these comments. Our CEOs are committed to protecting the solvency of the Medicare program, maintaining the promise of a safety net for current and future generations of Americans, and ensuring the fiscal health of our Federal government. We are asking that you withdraw this regulation and support strong beneficiary oversight activities to align the business regulatory requirements with those used in the private sector to ensure these programs are available. We believe that maintaining and building upon the public-private collaborations with both Medicare Advantage and Part D will play a substantial role in achieving these ends while improving quality of care and beneficiary health outcomes. We urge CMS to ensure that any future regulations and funding for these programs protect and bolster the role of private competition and innovation within these programs. We are available at your convenience to discuss any of these matters further.
Sincerely,
Gary Loveman
Chairman, Chief Executive Officer and President
Caesars Entertainment Corporation
Chair, Health and Retirement Committee
Business Roundtable