Federal and State Policy
As the largest US healthcare payer, the federal government plays a dominant role in shaping the healthcare marketplace, while states take center stage when it comes to developing novel policy approaches. Our experts track, interpret, and model policies that affect insurance coverage, access, and consumer choice so you can see around the bend.

Medicare Telehealth Expansion Amid Coronavirus May Have Long-Term Access Implications
New flexibilities for telehealth services in fee-for-service (FFS) Medicare are designed to support ongoing COVID-19 response efforts.
Over 1 Million MA Enrollees Are in Plans Offering New Benefits for the Chronically Ill in 2020
Medicare Advantage (MA) plans are using new flexibilities to provide additional supplemental benefits to beneficiaries with chronic illnesses.
Variations in Part D OOP Costs for Insulin Across the Year
Avalere analysis finds that average beneficiary out-of-pocket (OOP) spending for 3 commonly used insulin products remains similar throughout the year, ranging from $95 in December to $136 in June and July.
ESRD Patients Set to Enroll in MA in 2021 Differ in Key Demographics
Avalere analysis finds differences in the demographics of patients with End Stage Renal Disease (ESRD) enrolled in Medicare Advantage (MA) compared to ESRD patients in Fee-for-Service (FFS) Medicare
MS Patients Face High OOP Costs for Prescription Medicines
Avalere analysis finds that out-of-pocket (OOP) spending on prescription drugs for beneficiaries with multiple sclerosis (MS) could be as high as one third of their income.
CMS Proposed Changes to MA D-SNP Look-Alikes May Especially Impact Duals in CA MA Plans
Avalere analysis finds that many CA beneficiaries enrolled in D-SNP look-alike plans may not be able to a transition to a D-SNP.
Nearly 80% of Uninsured Population in Super Tuesday States Are Eligible for Assistance
New Avalere analysis finds that 76% of uninsured individuals lawfully present in the 14 Super Tuesday states are currently eligible for Medicaid, the Children’s Health Insurance Program (CHIP), or exchange plan subsidies.
Recent Federal Rule Could Undermine Some Patient Support Programs
The Center for Medicare & Medicaid Services (CMS) recently issued its proposed Notice of Benefit and Payment Parameters (NBPP) for the 2021 plan year. The proposed rule would significantly expand commercial payer flexibility to not count manufacturer copay support toward deductibles or out-of-pocket (OOP) maximums.
OOP Costs for MS Drugs Are Substantially Higher for Non-Employer-Based Part D Plans
Employer Group Waiver Plans (EGWPs) have lower out-of-pocket (OOP) costs for multiple sclerosis (MS) drugs than beneficiaries enrolled in other types of Part D plans.
CMS Proposal May Increase Obstacles for State-Mandated Benefits
In the Notice of Benefit and Payment Parameters (NBPP) for the 2021 plan year, CMS questioned whether states were appropriately deciding if the state was required to defray the premium impacts of new benefit mandates added since 2011. CMS proposes requiring states to report on and justify defrayal decisions for all state benefit mandates.
Patient Costs Among Medicare Part D Users of Mental Health Drugs
According to a new analysis from Avalere, Medicare Part D beneficiaries who are taking mental health drugs and do not receive low-income cost-sharing support are responsible for a higher share of the cost of mental health drugs (46%) than for non-mental health drugs (23%).
5 High Impact Areas in the MA Advance Notice & Proposed Rule
This month, the Centers for Medicare & Medicaid Services (CMS) proposed changes to Medicare Advantage (MA) through the annual Advance Rate Notice and Proposed Rule. These proposals impact MA in many ways, including changes to quality bonus payments, network adequacy requirements, coverage of End Stage Renal Disease (ESRD), plans targeting dual eligibles, and supplemental benefit offerings. Stakeholders should examine each of these areas closely as they respond to CMS.
CMS Proposes Allowing Part D Plans to Implement a New Preferred Specialty Tier
Implementation of a preferred specialty tier could have various impacts on Part D plans’ formulary and benefit designs and could affect manufacturer contracting strategies.
For the First Time, a Majority of Generic Drugs Are on Non-Generic Tiers in Part D
According to a new analysis from Avalere, Medicare Part D plans place generic prescription drugs on non-generic tiers 53% of the time in 2020.
Webinar: What’s Next for Medicaid Drug Pricing?
View the webinar recording to learn more about the latest policy, pricing, and reimbursement challenges in Medicaid.
States Choosing Healthy Adult Opportunity Program Will Need to Generate Savings to Stay Below Capped Funding Levels
New analysis from Avalere finds that states currently covering non-mandatory adult populations who choose to participate in the Healthy Adult Opportunity (HAO) initiative may need to generate up to 8% in Medicaid savings to keep spending below new capped funding levels.
2020 Election: Healthcare Coverage Landscape Varies in Early Primary States
As the early presidential primaries unfold, healthcare remains a top issue among voters. As recently as the November Democratic primary debate, polls showed that 24% of Democrats or Democratic-leaning independents said healthcare was the number one issue they wanted to hear discussed, ahead of the environment (12%), immigration (6%), jobs and the economy (5%), education (4%), and gun control (4%).
What to Watch for in this Week’s Call Letter and Proposed MA-PD Rule
CMS is set to release its annual proposed changes to Medicare Advantage (MA) this week. Some of the topics that may be addressed include End-Stage Renal Disease (ESRD), network adequacy requirements, payment to MA plans that offer the hospice benefit, and the MA quality bonus program.
CMS’s Healthy Adult Opportunity Program Includes Significant Changes to Medicaid Drug Benefit
The Centers for Medicare & Medicaid Services (CMS) announced the Healthy Adult Opportunity, a new Section 1115 demonstration initiative allowing states to shift toward capped Medicaid financing models with an opportunity for shared savings. If the option is chosen by states, it could be the largest change to Medicaid since the ACA.
Avalere Statement on CMS’s Healthy Adult Opportunity Program
CMS’s Healthy Adult Opportunity program, a new Section 1115 demonstration initiative, will allow state Medicaid programs to move toward capped financing models for some non-disabled adult beneficiaries with an opportunity for shared savings and additional flexibilities.

