CMS将投标引入2025年基于价值的保险设计计划

3health-related social needs. MAOs will need to react quickly torespond to this new requirement because applications for 2025are due April 12, 2024.Summary of new guidanceThe new guidance describes two application review phases, asshown in Figure 1.FIGURE 1: PHASES OF CMS COMPETITIVE VBID APPLICATION PROCESSPhase One Review1.Application Completeness Review:CMS will review theapplication to ensure all required elements are included.2.Screening for Eligibility and Program Integrity Risks:CMS will review the application to ensure the MAO iscompliant with all eligibility requirements identified in the2025 RFA.CMS has stated it will not consider exceptionrequests for CY 2025.Phase Two Review3.Scoring of Application Content and Potential forSavings:CMS will apply a scoring rubric (see Figure 2) toapplications based on a set of criteria in two categories: 1)Application Content and 2) Potential for Savings.4.Determination of Provisional Approval:Applications thatare found to be satisfactory based on application contentand potential for savings are reviewed for provisionalapproval.Process for Calendar Year (CY) 2025. Retrieved March 24, 2024, fromhttps://www.cms.gov/files/document/vbid-cy225-application-screening-scoring.pdf3This article considers information available through March 19, 2024. March 2024Applications that fail Phase Onerequirements will be rejected. CMS introduces competitive bidding into the VBID program for 2025Key questions, considerations, and risksCMS has also outlined a scoring rubric for its Phase Two review,which is shown in Figure 2.FIGURE 2: CMS VBID APPLICATION SCORING RUBRIC FOR PHASE TWOSECTIONSCORING DETAILSPOINTSApplication Content40Permissibility ofapplication proposals*Exceptional (all points), acceptable, orpoor (minimum available points)10Support for qualityimprovement plan**Considers whether the MAO presentsevidence thatallVBID benefits/RIprograms offered 1) have a beneficialimpact on quality and 2) drive medical costdecreases (excluding reductions in bidmargin)10Health equity plan*Exceptional (all points), acceptable, orpoor (minimum available points)10Innovation*Exceptional (all points), acceptable, orpoor (minimum available points)10Potential for Savings60Value of VBID benefitsand/or RI programs**Per member per month (PMPM) and perengaged beneficiary per month (PEBPM)rank of VBID benefits/RI Programs intoquintiles20Expectation of medicalcost savings (excludingsavings driven byreducing bid margin)**Exceptional (all points), acceptable, orpoor (minimum available points)20Support for savings**Considers whether the MAO presentsevidence thatallVBID benefits/RIprograms offered 1) have a beneficialimpact on quality and 2) drive medical costdecreases (excluding reductions in bidmargin)20Applications that do not receive at least 24 points in theApplication Content Section and 36 points in the Potentialfor Savings Section will be denied participation.* Reviewed in the VBID Application Spreadsheet** Reviewed in the Financial Memo and related documentsIn its Office Hours call on March 19, 2024, the VBID Modelrepresentatives from CMS stated they have not set a specificnumber of proposals that will be approved, but approval is reallybased on meeting these minimum score thresholds. However,they did not explicitly state that all MAOs that meet the minimumscore threshold will be accepted.4Defined as being eligible for the low-income subsidy (LIS) or, in the USterritories, being dually eligible. March 2024Questions for MAOs that choose toapply for VBID in 2025To respond to the new guidance, MAOs need to consider thevalue of VBID benefits to their 2025 plan offerings and decidequickly if their current VBID strategies will result in an acceptableapplication. Some key questions for an MAO to consider include:1.How impactful would it be if the MAO’s VBID application isnot accepted? Would plan enrollment be jeopardized in ameaningful way if competitors offer VBID benefits and theMAO does not (for example, popular benefits like food cardsor the elimination of Part D cost sharing)?2.Will the MAO’s VBID application achieve the minimum pointsnecessary to achieve a satisfactory score under theevaluation criteria?3.Does the MAO need to enhance its VBID strategy to addressthe key VBID application elements?4.Because the value of the MAO’s VBID benefits and/orrewards and incentives (RI) programs will be sorted withother MAOs into quintiles for scoring, are the MAO’s benefitofferings valuable enough to be approved?5.Do the Plan Benefit Packages (PBPs) included in theapplication strengthen or weaken the MAO’s overall scoringpotential under the rubric?Note as of the writing of thispaper, it is not known how CMS will calculate an aggregateVBID benefit value or apply other scoring criteria whenmultiple PBPs are included in an MAO’s application.6.Has the MAO assigned sufficient resources to ensure thatthe application is complete and in compliance with allrequirements in the VBID RFA and related materials?Key cons