The Centers for Medicare & Medicaid Service’s proposed update for Medicare Advantage and Part D prescription drug programs in calendar year 2017 includes, on balance, “fair and sustainable rates to help ensure patient access to vital health care services,” AHA said in comments submitted today. “However, we have concerns about several of the proposed policies, such as the rapid increase in the proportion of risk scores based on incomplete encounter data,” wrote AHA Executive Vice President Tom Nickels. The letter addresses several areas of importance to hospitals and health systems, especially those that offer MA and Part D plans, such as proposed changes to the risk-adjustment model, star-rating program and risk scoring.