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March 7, 2023 - The Academy provided feedback and recommendations to the Advance Notice of Methodological Changes for Calendar Year 2024 for Medicare Advantage Capitation Rates and Part C and Part D Payment Policies.

In the comments, the Academy called out the proposal to remove protein calorie malnutrition from the Hierarchical Condition Category Risk Adjustment Model. The Centers for Medicare & Medicaid Services has cited its rationale for removal of malnutrition diagnoses as it has determined them to be discretionary and should not be used as credible predictors of cost of care. The Academy argued the justification of continuing to include protein calorie malnutrition in the CMS-HCC, citing the following:

  • Patients who have malnutrition cost more during hospitalizations than those who do not;
  • Patients who have malnutrition when hospitalized or acquire malnutrition during the duration of the stay have worse outcomes than those who do not; and
  • Intervening with nutrition in patients who are diagnosed with malnutrition may improve health outcomes and subsequently save resources.

Inclusion of malnutrition-related codes into CMS-HCC models will provide more accurate estimation of true health care resource use. Out of concern that recent audits relating to malnutrition payments may be influencing CMS's proposal, the Academy strongly recommended that the solution to solving the malnutrition claim payment issue is not the removal of the Protein-Calorie Malnutrition from the CMS-HCC model, but rather CMS to provide a policy that delineates evidenced-based criteria for the identification of severe malnutrition and to invest in better training of its investigators to fully understand and apply the evidenced-based criteria for diagnosing malnutrition throughout the full continuum of malnutrition and care.

Read the full comments here.

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