AHA Responds to CMS Medicare Advantage Data and Audit Proposed Protocol

November 11, 2024

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
7500 Security Blvd
Baltimore, MD 21244

Re: CMS-10913 Medicare Part C Utilization Management Annual Data Submission and Audit Protocol Data Request

Dear Administrator Brooks-LaSure:

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations and our clinician partners - including more than 270,000 affiliated physicians, two million nurses and other caregivers - and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to provide comments in response to the Centers for Medicare & Medicaid Services' (CMS) proposed Medicare Part C Utilization Management Annual Data Submission and Audit Protocol.

The AHA appreciates CMS' interest in improving Medicare Advantage (MA) data collection and audit capabilities to increase transparency and oversight of the program as it continues to grow. We applaud the agency's recent rulemaking designed to improve consumer and beneficiary protections for MA enrollees and believe efforts to increase data collection, reporting, targeted auditing and transparency in the program will further advance these important aims. Indeed, as enrollment in the MA program has for the first time reached more than half of all people enrolled in Medicare, it is more important than ever to establish and implement stronger data-driven auditing and oversight capabilities.

The AHA has written extensively to CMS and other federal agencies in recent years, articulating serious concerns about the negative effects of certain Medicare Advantage Organization (MAO) practices and policies. ¹