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Medicare Advantage.  The Government Wants Your Comments.

Now is your opportunity to tell this administration that the steal from Medicare has to stop. Medicare Advantage only “advantages” the corporations that run it.

Now is your opportunity to tell this administration that the steal from Medicare has to stop. Medicare Advantage only “advantages” the corporations that run it.


The government has invited the public to comment on ways to improve Medicare Advantage (MA). The best the government can do is to STOP THE STEAL by immediately eliminating Medicare Advantage and its poisonous siblings Direct Contracting Entities/ACO REACH. You have until August 31st to comment. Here is the leading edge argle-bargle that the Centers for Medicare and Medicaid Services (CMS) is putting out: 

Through this Request for Information (RFI), the Centers for Medicare & Medicaid Services (CMS) is seeking feedback on ways to strengthen Medicare Advantage (MA) in ways that align with the Vision for Medicare and the CMS Strategic Pillars (​cms-strategic-plan). An additional goal of this RFI is to create more opportunities for stakeholders to engage with CMS, in line with the agency's Strategic Pillars that prioritize increased engagement with our partners and the communities we serve throughout the policy development and implementation process.

Joe is peddling private insurance - not Medicare

You can read the entire RFI here, at the site of the Federal Register. You will find the page for providing comments here. (Click on the blue COMMENT button at the upper right of the page)  Now, I am not discounting the possibility that there could be people with Medicare Advantage who are satisfied customers, but let's explore the MA program a bit, because the overall effect of its existence is to transfer of billions of dollars from the coffers of Medicare to private insurers with little or no concomitant advantage to the so-called “beneficiaries.”  

In spite of what Joe Namath may say on his MA commercials, Medicare Advantage is a contrived effort on the part of Congress and the Executive Branch to privatize your Medicare. Physicians for a National Health Program have dozens of articles on these privatization efforts. Here is a list of some of those articles to give you a taste of the extent of the problem.  (All 42 of the articles can be found here)

Private Medicare Advantage insurers sign up Medicare patients who have lower spending

The Disadvantages of Medicare Advantage (Read this if you have no time to read the other references)

Why Medicare Advantage costs taxpayers billions more than it should 

High-cost patients exit private Medicare Advantage plans 

CMS is giving unfair competitive advantage to private Medicare Advantage plans

Russell Mokhiber explains why private Medicare Advantage plans are a bad deal

Government insiders misappropriate funds to Medicare Advantage insurers 

Medicare Advantage Overpayments

Beware! Private Medicare Advantage for All is gaining momentum

CMS will likely continue to overpay Medicare Advantage plans 

A two-part article in Health Affairs, entitled Medicare Advantage, Direct Contracting, And The Medicare ‘Money Machine (PART I and PART 2) lays out this legalized robbery that is taking place right under the noses of all Americans. This has consequences for EVERYONE under Medicare as (let me say it once again) it diverts money that might otherwise be used for health care into the coffers of monied interests. This is the model…

“Supporters of MA (Medicare Advantage) point to the program’s growth as evidence that the privatized model works. The reality is that MA grows because the structural and risk-score gaming overpayments subsidize MA plans to offer some improved benefits, lower Part D costs, an average $5,000 out-of-pocket cap, and underutilized supplemental benefits. Low-income beneficiaries remain underinsured and subject to significant copayments and deductibles. As plans code more, risk scores go up, CMS provides more subsidies, benefits and premiums get better, and buyers choose the improved plans that cost taxpayers more. This is one distorted dynamic in the MA marketplace: the costlier the plan is to the payer (CMS), the easier it is to sell it to the customer, and the greater the profit.”

Catch 22

This is almost as exquisite as Catch 22 from Joseph Heller's book by the same name, but in the case of MA it is your money that is at play and those paying into and using Medicare lose eventually, no matter what, because privatization eats away at the Medicare fund. It is widely known that the overhead for Medicare, (what it costs to run the program,) is about 1%. The privateers, once let loose on the Medicare funds, run operating cost percentages into double digits.  

So it is not a question of how to improve Medicare Advantage, it is a question of completely eliminating MA in order to preserve Medicare for the future. I have provided above many opportunities to read about these privatization efforts. Let CMS know that you are on to the scam by making your comments today!

Comments by Readers

Kerry Johnson

Aug 12, 2022

thanks much for keeping up with issue, Mr. Conoboy, and keeping us informed!


Dick Conoboy

Aug 12, 2022


You are welcome!  Don’t forget to comment on the RFI site. STOP THE STEAL!


Kerry Johnson

Aug 12, 2022

I found the hardest part of the ‘form’ was deciding what “category” my comment fit into.  I ended up choosing “other”.  (Any recommendations on this?)

I’m a little more radical than most folks that I know.  Here is what I submitted:

It’s difficult to write about this topic while remaining ‘civil’—the whole mindset and proposal are entirely wrongheaded, and ultimately anti-human.  We need a “national, universal health service”, and not even bother with any sort of ‘insurance’.  Those who cannot ‘see’ this obvious ‘solution’ are ‘well indoctrinated’, ‘entrenched’, and ignorant of economic dynamics, trends, and anti-social manipulation, and cannot fathom a future that is ‘beneficial for all’.  Please start these efforts over, beginning from a genuine understanding of human needs, and how a government can provide such.  I thank you.


Dick Conoboy

Aug 12, 2022


No recommendation as I have not yet filed my comment ... which is now being drafted.  If I find out anything more, I will let the readers know.



Dick Conoboy

Aug 12, 2022

 To my readers,

 Kerry’s question is a valid one.  I would select Health Care Industry Pl015 as the category.

Within your commenting, refer to file code CMS-4203-NC.


Pat Britain

Aug 12, 2022

Hi Dick, I will be crafting my response and submitting it tomorrow. I’ll post it here.

THANK YOU for alerting all of use to this opportunity to convey of our opinions (in my case disgust) about Medicare Advantage and ACO/REACH. 

Pat Britain


Dick Conoboy

Aug 12, 2022


Remember that this is about Medicare Advantage.  ACO Reach is another program.



Pat Britain

Aug 12, 2022

I remember. Medicare Advantage is what got me started on this issue of privatization. It was Kaiser Medicare Advantage that declared all of the primary care physicians in Whatcom County that were not working for Peaceheath or Family Care Network as out of their network - and that included my primary care doc, Mitchell Kahn, the best doc that I ever had for primary care. As a result, I dumped MA for traditional Medicare, but Dr. Kahn closed his practice as so many of his patients were on Kaiser MA. The lesson I learned is that Medicare Advantage restricts their customers to a “preferred network” and there is no coverage for doctors, clinics or hospitals outside of their network. And Medicare Advantage insurers can, and do, change the entities that they declare “in network”, with a very limited amount of notice.

If you have Kaiser Medicare Advantage (as well as some other MA plans), some of the best providers in the state, such as Cancer Care Alliance (the best place in the Northwest to go if you have cancer) or University of Washington Medicine (tops in many catagories of heathcare), are out-of-network. I was really glad that when I needed to go to UW Medicine (because care in Bellingham was so limited), I had traditional Medicare and the cost of my care there was covered.

Yup, I have stuff to say about MA. ACO/REACH is just another iteration of the CMS drive to privatize Medicare. It’s just not enough that 48% of Medicare is privatized under MA; ACO/REACH is bent on privatizing the care of the 52% of us on traditional Medicare (where I am today).

Pat Britain


Pat Britain

Aug 12, 2022

So, when you read this, one just has to wonder why CMS still appears to embrace Medicare Advantage which is clearly not getting their job done.

 The U.S. Department of Health and Human Services Office of the Inspector General put out a report on 4/27/22: 

Some Medicare Advantage Organization Denials of Prior Authorization Requests Raise Concerns About Beneficiary Access to Medically Necessary Care 

Here’s the link:

“Our case file reviews determined that MAOs sometimes delayed or denied Medicare Advantage beneficiaries’ access to services, even though the requests met Medicare coverage rules. MAOs also denied payments to providers for some services that met both Medicare coverage rules and MAO billing rules. Denied requests that meet Medicare coverage rules may prevent or delay beneficiaries from receiving medically necessary care and can burden providers. Although some of the denials that we reviewed were ultimately reversed by the MAOs, avoidable delays and extra steps create friction in the program and may create an administrative burden for beneficiaries, providers, and MAOs. Examples of health care services involved in denials that met Medicare coverage rules included advanced imaging services (e.g., MRIs) and post-acute facility stays (e.g., inpatient rehabilitation).

Prior authorization requests. We found that, among the prior authorization requests that MAOs denied, 13 percent met Medicare coverage rules; in other words, these services likely would have been approved for these beneficiaries under original Medicare (also known as Medicare fee-for-service). We identified two common causes of these denials. First, MAOs used clinical criteria that are not contained in Medicare coverage rules (e.g., requiring an x-ray before approving more advanced imaging), which led them to deny requests for services that our physician reviewers determined were medically necessary. Although our review determined that the requests in these cases did meet Medicare coverage rules, CMS guidance is not sufficiently detailed to determine whether MAOs may deny authorization based on internal MAO clinical criteria that go beyond Medicare coverage rules.

Second, MAOs indicated that some prior authorization requests did not have enough documentation to support approval, yet our reviewers found that the existing beneficiary medical records were sufficient to support the medical necessity of the services.

Payment requests. We found that, among the payment requests that MAOs denied, 18 percent of the requests met Medicare coverage rules and MAO billing rules. Most of these payment denials in our sample were caused by human error during manual claims processing reviews (e.g., overlooking a document) and system processing errors (e.g., the MAO’s system was not programmed or updated correctly).

We also found that MAOs reversed some of the denied prior authorization and payment requests that met Medicare coverage and MAO billing rules. Often the reversals occurred when a beneficiary or provider appealed or disputed the denial, and in some cases MAOs identified their own errors.”



Dick Conoboy

Aug 12, 2022


Thanks for those revelatory comments.  I am still in Traditional Medicare and intend to stay there.


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