The Centers for Medicare and Medicaid Services (CMS) recently released its 2019 proposed policy changes to the Medicare Advantage and Part D (MAPD) program1. Among the purported changes, CMS is proposing to relax the uniformity rule for all MA plans, allowing carriers to offer a varying set of MA benefits within the same plan ID2 (previously all members within a plan ID must have the same level of cost-sharing). Prior to this proposed rule, only plans who requested a waiver of the uniformity rule through participation in the MAPD value-based insurance design model (VBID) were allowed to offer varying benefits within a plan ID. This subtle change could have major implications on the viability of the VBID program as well as modifications to the 2019 bid submissions. This paper will discuss the differences between the VBID demonstration and the proposed rule, as well as potential pitfalls to the 2019 bidding process.

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