On Monday, APMA submitted comments to CMS on the Advance Notice of Methodological Changes for Calendar Year (CY) 2026 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies. APMA again advocated for the importance of care for diabetic beneficiaries and pushed CMS to consider enhancing measures that support this care.
APMA is pleased to hear that CMS is considering potential new measure concepts and methodological changes including the Diabetes Foot Exam and Follow-Up (Part C). As APMA is aware, NCQA is developing a new measure that assesses comprehensive foot examinations (neurological, vascular, visual) and appropriate follow-up for abnormal findings among adults with diabetes, which will be implemented as an ECDS-reported measure that leverages multiple data sources (i.e., claims, electronic health records, health information exchanges, registries). APMA has been involved in these efforts. APMA also reiterated our support for a Star Rating or other measure that incorporates elements of APMA’s Comprehensive Diabetic Lower Extremity Exam (CDLEE). To read the letter in its entirety as well as other APMA comments, visit www.apma.org/comments.
As previously reported in APMA Weekly Focus, in January APMA submitted a response to CMS's proposed rule, “Medicare and Medicaid Programs; Contract Year 2026 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly.” In APMA’s response, our comments focused on the sections related to Improving Access—Enhancing Rules on Internal Coverage Criteria and Enhancing Health Equity Analyses: Annual Health Equity Analysis of Utilization Management Policies and Procedures. APMA reiterated transparency concerns related to Medicare Advantage Organization (MAO) plans’ coverage and payment policies, particularly that MAO plans are reducing and/or denying payments for services otherwise covered under Medicare fee-for-service.
If you have questions or concerns, contact APMA’s Health Policy and Practice department at healthpolicy.hpp@apma.org.