Dear Administrator Brooks-LaSure,
The Alliance of Specialty Medicine (the “Alliance”) represents more than 100,000 specialty physicians across 16 specialty and subspecialty societies. The Alliance is deeply committed to improving access to specialty medical care by advancing sound health policy. Our organizations write to share collective insights and recommendations in response to CMS’s Request for Information on Medicare Advantage (MA) data, emphasizing our commitment toward ensuring beneficiaries enrolled in MA plans have access to high-quality, specialized care. With the increasing number of beneficiaries choosing MA plans, it is paramount that CMS improve its policies to ensure the health needs of this growing population are being met, particularly where specialty medicine is concerned. As such, CMS must improve the availability of data and information for beneficiaries and the public to evaluate MA plans.
Beneficiary Access to Care
The Alliance remains concerned about access to specialty care for beneficiaries enrolled in MA plans. As we have shared previously, MA plan networks are woefully inadequate, in part because not all specialty and subspecialty providers are “counted” in CMS’ quantitative standards. Additionally, MA provider directories remain largely inaccurate, as evidenced by multiple agency studies, including those by CMS, which is exacerbated by CMS’ failure to strictly enforce its requirements or impose financial and other penalties.
We have suggested several regulatory reforms that would mitigate some of these challenges, as discussed in detail below, and urge CMS to adopt these in the next rulemaking cycle (i.e., 2026). These recommendations all share the goal of improving the availability of data and information for beneficiaries and the public to evaluate MA plans.
Update the “specialty types” that plans must ensure meet CMS’ time/distance standards so that additional specialties and subspecialties are considered. CMS holds MA plans accountable for 29 specialty types in its network adequacy standards, yet there are many more recognized specialty and subspecialty types. For example, the American Board of Medical Specialties (ABMS) oversees 24 Member Boards that represent 40 medical specialties and 89 subspecialties, while the Association of American Medical Colleges (AAMC) recognizes more than 160 specialties and subspecialties in the United States, including many recognized by ABMS-equivalent certifying boards. By not considering the full range of specialists and subspecialists in its network adequacy standards, CMS has allowed plans to avoid responsibility for true network adequacy.
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