RUPRI Health Panel Comment Letter on Medicare Advantage Program

The RUPRI Health Panel has responded to a CMS Request for Information on the Medicare Advantage program.


Rural Perspective on Medicare Advantage
Our comments and feedback are offered from the rural perspective, where Medicare Advantage is an increasingly important source of health care coverage. As of March 2022, MA accounted for 45.7 percent of all Medicare beneficiaries. In rural America, 4.3 million beneficiaries were enrolled in MA plans, 38.8% of all rural beneficiaries. While that percentage is lower than urban and overall percentages (47.2 percent and 45.7 percent), the rate of enrollment growth is higher in rural America, 13.4 percent compared to 7.9 percent in metropolitan counties between 2021 and 2022. [Data are taken from a draft of a RUPRI Center for Rural Health Policy Analysis policy brief currently under review; the previous brief presenting data through 2021 is available here; ( the current brief will be available from the same site soon.] MA plan enrollment is uneven across states and regions, reflected in the RUPRI Center for Rural Health Policy Analysis state choropleth map ( enrollment in non-metropolitan counties. Rural enrollment is below 18 percent in nine states and between 18 percent and 25 percent 11 states; it exceeds 44 percent of beneficiaries in nine states. This variation reinforces our earlier point that actions taken in the MA program will have geographically varying impacts.

Lower enrollment in MA plans in some areas is related to both supply and demand issues related to plan availability and affordability. In particular, in areas with lower populations, plans face diseconomies of scale, which raises the costs of MA plans. This can lead to higher premiums for the plans or fewer plan benefits, reducing demand for the plans.

Our reason for citing these data is to make two points supportive of the proposed actions by CMS: 1) the immediate impact of actions in the MA program will be greater in urban than rural (metropolitan vs. nonmetropolitan) areas, making it more important in rural areas to continue leveraging the Traditional Medicare program to achieve similar objectives; and 2) the more rapid MA enrollment growth in rural counties points to the importance of taking advantage of actions intended to achieve strategic plan objectives through the MA program by focusing on particular needs in rural places.