The AHA today submitted comments on the Centers for Medicare & Medicaid Services proposed changes to the Medicare Advantage and Part D prescription drug programs for calendar year 2018. “We agree with CMS’s proposal not to move forward with plans to increase the proportion of the risk adjustment scores that are based on encounter data,” wrote AHA Executive Vice President Tom Nickels. “However, we have ongoing concerns both about the use of encounter data for purposes of risk adjustment and the continued calculation of benchmark caps after inclusion of the quality bonus payments. We also provide additional considerations regarding how to address high and rising drug prices in the Part D program.”