Good morning, everyone. Welcome to the Wells Fargo Health Care Conference. I'm Stephen Baxter, the services analyst here. We are pleased to be joined by Humana, a leading health plan focused on Medicare Advantage, and increasingly, its portfolio of services capabilities. From the company, we have Bruce Broussard, CEO, Susan Diamond, CFO, and Lisa Stoner from Investor Relations. Thank you very much for, for being here today.
Thanks for having us.
We really appreciate it. Of course. So just to kind of get this one out of the way, we saw you put out 8-K this morning. Obviously, utilization's been in a huge amount of focus over the past couple of months. Can you give us the latest on what you're seeing on the utilization front, since you provided us an update on the second quarter call?
Yeah, sure, absolutely. And as you said, we reaffirmed guidance this morning. As we said in our second quarter call, you know, we were really pleased to see with our June claim restatements that they sort of validated the moderating trends, particularly in the non-inpatient space, that we had been expecting. And we knew going into the second quarter call there were some open questions about that in light of what some competitors had indicated that they were seeing in terms of trends, and whether the higher percentage trend year-over-year would, in fact, continue or moderate, which we had anticipated, which was really more a function of the curve of the prior year PMPMs that we were seeing as we came out of the COVID surge in the first quarter.
So as we said on our second quarter call, you know, the June paid claims validated that the estimates that we had relied on, that did assume more moderating trend levels, although on an absolute basis, an expectation that that higher non-inpatient PMPM would continue. We did see those trends emerge, and those were further validated and supported by the July claim restatements that we saw. As we did say at the time, we were seeing a little bit of an uptick in the inpatient side.
We have continued to see that, but in recent weeks, you know, things have been relatively comparable to what we described in the second quarter, with the exception of we have seen a further slight uptick in the inpatient side related to COVID, which is consistent with what you've probably seen and read about in the, in the news lately. I would say that's still within the range of what we would have assumed in terms of our estimates, that allowed us to provide our second quarter update and then the, the reaffirmation of guidance this morning. We did, within our estimates, assume that we would see an uptick in COVID, although we had assumed that it would occur in the fourth quarter.
So arguably, this is probably a pull forward of what we would have otherwise expected to see in the fourth quarter. We'll certainly continue to moderate it, but all in, I would say the claims and the latest information continues to support the estimates that we've been sharing.
Got it. Thanks. That's very helpful. And then just as you developed guidance for the back half of the year, could you just remind us how you approach things like seasonality, workdays, kind of cadence around, like, whether physicians are taking holidays? Just remind us how you kind of built all into your guidance this year.
Yeah, I would say the seasonality for holidays, you do see that typically in July and then a little bit just in the summer with vacation schedules, which is pretty consistent. And we'd say that's nothing surprising in terms of what we've seen so far. You'll certainly see some of that around the holidays. It'll occur in, you know, November and December. And then otherwise, you do have a workday seasonality pattern this year, where you see a higher number of workdays in the first half versus the back half. So that is something we would always consider and contemplate in our claim estimates. In terms of the trend we're seeing, as we've described, we continue to anticipate that the higher non-inpatient trend and then the slight uptick in inpatient will persist through the end of the year. So we're not counting on that to mitigate.
We're assuming that that will continue, whether that's due to improved productivity or healthcare capacity of some kind, but that, that we're not expecting that to abate, and frankly, through 2024 as well. We're assuming that that will, will continue through 2024.
Okay. And you spoke a little about this on the second quarter call, but as you've had more time to look at it, in terms of the higher utilization, could you just tell us a little bit about, you know, whether there's pockets of your membership, whether it's, you know, the population that you're experiencing growth in this year, whether it's, you know, risk versus non-risk populations, any kind of different dynamics we should think about in terms of the way utilization is playing out?
Sure. I mean, we certainly do have with the mix of membership, that'll impact sort of what we assume in our estimates. And as we've mentioned, you know, really pleased to see the higher age-in share that we've benefited from within our stronger enrollment this year, which the last number of years we have not garnered our fair share. So that was a priority for 2023, and really pleased to see that. And from a long-term perspective, just given the way the reimbursement model works, arguably, you know, that population is underfunded in the first couple of years.
Mm-hmm.
And then once they switch to full risk adjustment, then you have disproportionate margin growth potential for that cohort. So that higher enrollment this year, which we didn't initially anticipate, and Bruce shared some comments during the second quarter call about the uptick in share that we've seen, you know, that will put some pressure on the MER.
Mm-hmm.
They do have overall lower claims PMPM, but also meaningfully lower revenue. But it does put some MLR pressure, which we've contemplated in our forecast. But certainly positive to see that, and then we'll see some, you know, improvement in the years to come. Otherwise, I would say... I apologize, what-- remind me of your first question?
It was just gonna be whether you saw different utilization-
Oh, different patterns.
patterns across the... Yeah.
I would say broadly, the trends that we're seeing are broad in nature. They're not-
Okay
... disproportionately in a certain geography or certain population. I would say just slightly elevated across the board.
Okay.
We have commented that we are not seeing it as much in the risk space. It's more in the non-risk space, which, given some of the category trends that we've pointed to in terms of the, you know, elective surgeries, ER, and observation stays, those we would argue that the risk-based providers tend to manage better in normal course, which could be a reason why we're just seeing less of it in the risk space than the non-risk. But otherwise, we would say no single driver and more broad in nature, and just a slight elevation relative to what we would have expected.
Okay. And then thinking a little bit about 2024, Bruce, you know, I think we were all waiting to hear what you guys thought about industry growth potential for membership in MA in 2024. Can you give us a little bit more color on why you expect industry growth to remain strong in 2024, with the potential for benefits to pull back at the industry level? Would love to, obviously, the, the relative value of, of MA remains quite high, but to the extent that's also informed by, you know, potential Part D conversions, maybe an above average rate, would love to just hear what gives you the confidence in-
Yeah
in that industry level growth rate.
...Well, as you mentioned, we continue to see the value proposition between Medicare Advantage and Medicare Fee-for-Service to be significant, about $2,400 in value. And so we continue to see individuals wanting that value through the MA side. The second thing that we've seen, and changes that we've faced over the last decade or so in the structural and in payment models, is that we've seen growth in, you know, in the 2011-2015 time range, and we saw a lot of changes, and then that continued for the next three or four years after that. And we saw growth, and growth from 25%-35% of the industry there.
So even in times of change, the value proposition continues to stay high, and we look at that this year as being the same. And when people enter MA, they really don't have a historical perspective of it, the individuals that are there currently. And what we've seen in the way we've structured our benefits is to really try to understand what the top benefits are and not alter those as much and put value where they consider to be significant value there. So we continue to have a strong view that this will be another good growth year for MA because of the value proposition, managing the changes in a way that's more consumer-friendly. But that being said, there will be shopping that happens.
Yeah.
That shopping, I think, will endear to individual, I mean, individual companies that have the benefit package that has the most value.
Okay. As you think about potential evolution of the Part D market, I guess what kind of feedback are you hearing, and maybe from the broker channel, on how they might be approaching people that have traditionally approached coverage with, you know, supplemental coverage in Part D? Like, do you think there's going to be a meaningful shift there into MA for the next few years? I guess, how do you see that playing out?
Yeah, we've seen, just over the years, you know, a shrinking Part D industry, and it's being really a result of the people going to MA, and we-
Mm-hmm.
Continue to see that being a trend. This year and next year, there's just substantial changes happening in Part D, and so the predictability of it is a little lower. Obviously, the benefit of the MOOP is a significant change for the consumer in favor of the consumer.
Mm-hmm.
That is also being subsidized by the federal government through their subsidy program. So I would, I would say let's sort of wait and see over the next few years on how it, changes. But I think the value proposition overall for MA, continues to pull from the Medicare fee-for-service and, and, and diluting Part D overall.
Got it. And then as you guys approach 2024 in your bids, obviously, a lot of moving parts around the utilization experience you're having this year. Also, the desire to, you know, potentially realize some of that above-market growth potential. Like, how did you manage the dynamic between ensuring that margins are going to be where you need them to be to grow at your 11%-15% EPS rate next year, and also deliver on above-market growth-
Yeah.
-in a year where you're kind of repricing?
Yeah. Obviously, the risk adjustments that were brought on this year also creates the complexity of it. A few things there. As I mentioned just on the previous question, is prioritizing what the value is to the customer to be most important, and how we structured the benefits there. And so we really were very thoughtful around how do we create as much stability within the benefit structure, but still being able to support the financial profile of our company. I think we've done a really good job on that.
Okay.
The second thing that we've seen is just the brand of Humana over the last 18 months has really caught hold, and we see a really strong relationship with our brokers as a result of the stability of our benefits, but also the forecasted stability, specifically through the Stars program, and then being able to foresee, you know, a stable benefit going forward. And then the second thing that we've also seen is the service side and our Net Promoter Score has really given them security that if someone does come to our company, that the changes... I mean, that they are going to feel supported, and the service is going to meet the needs of the customer.
And they've been concerned, in some of our competitors, that they, that there's just been some, the ball dropped a few times, and, and then the, the customer gets frustrated and gets frustrated at the recommendation of the broker. And then the last thing I would say is, is not only did focusing on the customer side and then, in addition, the broker, is the, the third thing that we see is the ability for us to continue to grow, as a result of our value-based relationships and the, and the stability of that, and the growing of that, combined with our Stars program, gives us a competitive advantage in the way we can price.
Okay. And then, as you guys have gotten a better sense of the competitive landscape over the past few weeks and gotten feedback from brokers, what are you hearing? I guess, how does what you're hearing compare to what your initial expectations might have been? And then is there anything to call out, whether it comes to, you know, maybe some competitors or, or potentially retrenching around duals or maybe the non-dual space feels like there's more white space for you in 2024? I'd love to just hear how that's all shaping up.
Yeah. I would say in the duals area, these SNPs, there's probably a little more investment than what we thought there. We're still competitive and feel very comfortable with it, but we were surprised a little bit, just in some of the investments and changes people, organizations have made. So that area is a wait and see, but we feel comfortable that we're still going to grow-
Mm-hmm.
Well, but maybe just not at the level that we first anticipated. In the non-dual space, I think this is an area which is the largest part of the market.
Mm-hmm.
We feel really good about it. We think the positioning and, you know, Susan was talking about the age-ins this year is really a result of our product positioning, and we see that continuing in 2024.
Okay. Is there any reason to think that, that the mix of age-ins could change in a meaningful way for next year? Obviously, that does have a pretty significant impact on, on the PNL. I guess, how are you guys thinking about age-in dynamics for next year?
Yeah. So I would say, as Bruce mentioned, we have seen where some of our competitors have emphasized duals in the D-SNP-
Yeah
-for 2024, which makes sense. It's a smaller population, so if you're going to put some investment to work, you can have more impact in that smaller population, and it continues to grow given the potential for penetration there. So while we haven't seen the full landscape data, and we're anxious to see that when CMS releases it the first of October, our guess is that there's probably been more degradation than across the non-dual benefits in order to fund some of the, you know, what would have otherwise we would expect, you know, higher benefit degradation in the D-SNP.
So we're anxious to see that, but arguably, given the strength of how we're positioned in 2023 and how we took a very balanced view to continuing to position ourselves for broad growth in 2024, I would expect that we will continue to do well within the age-in population. And we've assumed that as we think about 2024, that much like we saw in 2023, that we'll continue to do well with that age-in population. And as I said, the long-term and lifetime value potential for that population is very attractive. So we were very conscious of setting ourselves up for the opportunity for disproportionate growth. If we do, in fact, see the level of shopping that, that Bruce referred to, that we would anticipate, given the, the disruption that the risk adjustment model will likely introduce.
Got it. And just to follow up on that, I guess, can you talk a bit about how the, the mix of membership growth that you see in 2024 could potentially influence, you know, where you might land or where you might think about landing in terms of the 11%-15% EPS growth that you're targeting for next year?
Sure. Typically, we wouldn't comment on 2024 this early in the year. We did choose to provide some commentary on the second quarter call, just recognizing that given we acknowledged we did not fully price for the higher trend that we were seeing, you know, late in the bid process. You know, as we've had more time to evaluate sort of the source of that trend and how it might persist into 2024, and then for us to also assess, you know, all of our other line of business performance, the continued progress that we're making on productivity initiatives. We've had some positive tailwinds from investment income and other things. As we were able to assess all that, we felt comfortable at least reaffirming that we would expect to be within our historical 11%-15% EPS growth range for 2024.
That was really more to eliminate any concern that we might be below that range, which is some of the concern that we were hearing from investors. So I wanted to reinforce confidence in that. I would say again, still too early to comment specifically on where we might be for 2024, and we would typically give a little bit more commentary on our third quarter call, which we'll do this year. But I would say, you know, two of the main things that we'll continue to watch is certainly the current year emerging trend. How does that ultimately complete for the year relative to what we've expected, and how do we consider that? And then certainly, how the level of membership growth and then the mix of that growth, as you suggested.
And so to the degree, we do see, you know, disproportionate share in age-ins, and different, you know, geographies and plan designs, we'll want to assess as we think about what is then the, the implication to 2024. We remain committed to the targets that we laid out for 2025, including the $37 of EPS. And as we've always said, you know, outpacing the market in MA growth is one of the most positive things we can do in support of that goal. So all of that is very positive, but we acknowledge we'll have to continue to watch the trends, see how that emerges for 2024, and then ultimately, that we'll have the opportunity, if we need to, to take any further pricing action. In 2025, we certainly have the opportunity to do that.
Got it. And then obviously, a big part of, you know, being able to sustain this year's financial targets has been leaning a little bit more on the SG&A leverage side of things. I guess, just give us an update on how you're thinking about that going into 2024 and 2025. Do you consider that those savings largely become permanent, and that's kind of the new baseline that we're thinking about? Is there anything that we should be mindful that needs to reestablish itself as we move into 2024 and 2025?
Yeah, I would say we've been really pleased with the additional productivity progress that we've seen. You know, obviously, our value creation goal was very successful, delivering, you know, slightly more than $1 billion of savings we targeted on a run rate basis for 2023. As we had acknowledged, as we shared progress against that goal, there were a number of things that we knew would provide incremental benefit into 2024 and even 2025 that just took longer to implement. So things that required technology enablement, workflow redesigns, and some other things. So all of that work has certainly continued and led us to believe, even at the time that we did pricing, that there was more opportunity for 2024 than just the 20 basis points of operating leverage that we had committed to in the targets we laid out in 2022.
So that was something that we certainly were able to consider in our 2024 pricing, which, as we said, you know, was one of the ways that allowed us to mitigate what maybe would have otherwise been higher benefit changes that again, should position us hopefully for strong growth again in 2024. As we've continued that work, we've continued to see additional opportunity to streamline operations, you know, leverage a variety of tools where we do think for at least the next year or two, there is some disproportionate opportunity for further productivity beyond just the 20 basis points. And that's, again, another lever that has allowed us to offset this higher trend that we've seen this year without compromising membership growth or ability to continue to deliver the EPS progression that we've committed to. So I would say we continue to feel really good about it.
I think our leaders continue to feel really good about it. And I'd say the next year or two, some further disproportionate opportunity, and then we'll probably be more of a mature basis where we'll see more of the incremental 20 or so basis points going forward.
And then as we think about, you know, Star Ratings, we'll, we'll get soon for payment year 2025. I believe the companies have some data back on that. Obviously, don't have the final ratings or I don't think the cut points yet either, but would love to just get a better sense of maybe how you're thinking about 2025. I know in 2024 you were able to increase the Star rating on your largest contract, which gives you a bit more of a buffer. But any early thoughts on how we should be thinking about 2025 Stars would be, would be helpful.
As you mentioned, we've gotten our first look added, and we said this in the second quarter call, we feel comfortable that we're going to continue to lead the industry in Stars. And you know, in the next few days, we'll be able to see the cut points and understand that further. But what we've seen, we've you know, in our results, both on our satisfaction scores in the HEDIS area, especially, we've just you know, continues to reaffirm our confidence.
Then switching gears a little bit. You mentioned on the second quarter call that Medicaid was running, I think, a bit favorable to your expectations. It was one of the things that allowed you to deliver despite the higher MA utilization. I guess when you say Medicaid's running, you know, favorable, I guess kind of what does that mean? Is it the membership side? Is it, you know, the acuity side of things maybe is not transitioning? I know you guys have new contracts you're implementing as well. I'd love to just get a quick update on how your Medicaid business has performed and continues to perform.
Yeah. On that, Dave, we're running ahead on the redeterminations in a slight way, but we continue to believe that our retention will be about 20%, and as it all shakes out, and that, and so, so our performance is a little bit favorable as a result of the redetermination. But probably the larger part is the utilization.
Okay.
Just seeing a better utilization in the Medicaid area, and that has, you know, persisted for the last few quarters. You know, we know at some point in time, there will be a pricing that will then be reflected and adjusted for that, which normally happens both-
Mm-hmm.
- when it's positive or negative, but we feel that will be in the normal, cycles that, that goes through in the repricing side of the-
Mm-hmm.
of Medicaid.
Okay. The company's done, you know, tremendously well on Medicaid RFPs over the past few years, and I think that's probably been a pleasant surprise to everyone. You've had as much success as a non-incumbent as you've had. What do you think has allowed the company to win these RFPs? What's the feedback you're getting from states?
Yeah
on why they're choosing you?
Yeah, there's a few things that that relates to it. First, I think, just as I mentioned on the customer side, the brand stands out as really taking care of vulnerable populations, and that has always been sort of where we've, you know, led with. But the specific components of it... I think my microphone is going in and out here, so-
Oh, okay then.
- I'll speak down like this. I don't want to have, but I think the, the components that are probably most important would be the area of social determinants of health. We've really sort of led the industry in that. Our value-based relationships are another area-
Mm-hmm
- where it's been a standout. Then I would say the third is our clinical programs and our relationships with the state agencies. That sort of has stood out. You know, when they reference us in our existing relationships that we have, we just get great support from our referencing. So I do believe it's a combination of those, but it really stands out where we have been able to compete on the Humana Medicare Advantage side.
Okay. And then to ask about, you know, CenterWell and the primary care business, obviously there's going to be a bit of a transition on that side of the business as you move into the risk model. I guess from Humana's perspective, I guess, how are you expecting the risk model transition to work?
Mm-hmm.
I know you've expressed confidence that over a multi-year horizon, I believe you think you can offset the, the changes that are coming. But I guess, how does this work from your process? What are the key levers that you're going to need to, to focus on, to be able to drive towards managing through that over time?
Yeah, as we've mentioned in the past, we're just taking an estimate from a report that the industry analysis of how providers will be impacted between 10%-20%.
Mm-hmm
has been sort of the estimate. And that's of revenue. We have probably in the lower part of that estimate there. When we, when we've looked at it, and our teams are working hard to mitigate all of it over the three-year implementation, about a third of it is going to be a result of plan design changes.
Mm-hmm.
So, the payer side will pick up about a third of that through the benefit changes. The other two-thirds will be a combination of cost structure, just, you know, leveraging the cost structure and gaining more productivity out of that. Clinical changes, and the way the processes work there, gaining some more efficiencies in the physician area and in the nursing staff. And then the third area will be around risk adjustment and being able to-
Mm-hmm
to really understand what is the proper way to document, and then with the new rules being there, considering all the changes and both the ones that are being modified, but also being dropped off.
Okay.
But we feel very confident that we can mitigate all the changes.
Okay.
And just to clarify, we've said it'll take, though, time. So right-
Mm-hmm.
We are anticipating a headwind in 2024 within our primary care business. It's not material overall to Humana, but we do think with the mitigation strategy that they've created within the 3 years over which the full impact will be implemented, that by the end of that, that they will be able to fully mitigate that if they can execute against the plan that they designed. But we are anticipating a headwind in 2024, and then further in 2025, until the full mitigation can be realized.
Okay, so it's not like it's one-third phased in, and you have one-third offsets in the first year-
Mm-hmm
- and then one-third, one-third-
It'll just take some time for some of those changes that Bruce mentioned to be fully implemented and realized.
...And then as you think about, you know, the build-out of that business longer term and the company's, you know, plan to eventually buy back from Welsh Carson and consolidate onto the balance sheet, is any of the pace of expansion or the timeline towards those transactions, is that in any way impacted by, you know, this risk model transition?
Yeah. So we designed that structure where the intent had always been to bring those assets back on balance sheet at the time they reached breakeven profitability. So that is something we will watch. If we find that, you know, especially that first cohort, because of the risk adjustment model phase-in, we may decide to push that back a year before we bring it back on balance sheet. Now, again, within the, you know, the mitigation plan that we've talked about, you know, growth of patient panels is one of the most significant levers we have, and so a lot of focus on can we further accelerate growth within those panels? If we're successful in doing that, then it's possible that we could stay on the original timeline.
But if need be, then we do have the flexibility where we can push that out and would not have any material impact to Humana overall, and something we'll continue to watch, and have talked with Welsh Carson about that as we watch and see how the mitigation plan is executed.
Okay. And then just thinking about the other areas of the CenterWell and the home health side, there's obviously a lot going on. You know, the fee-for-service business, I think you've mentioned there's, like, a little bit of pressure on certain aspects. So, you know, like recertifications, for example. You also have a big initiative where you're rolling out value-based care as well, and some, some EBITDA contribution targets that you have set out. Would love to just hear an update on, on how home health is going post the acquisition and kind of where you guys are at that part of your strategy.
Sure, Jim, yeah.
Okay.
So I would say, as you pointed out, there are some challenges within the fee-for-service business, both on the reimbursement side, where, you know, the company is seeing strong new admission growth. But across the industry, I think home health agencies on the fee-for-service side are seeing some pressure then on the recertifications, where health plans are implementing utilization management and other strategies that are then offsetting some of that new admission growth. We obviously saw the preliminary rate notice, you know, that was negative, and I would say more negative than we would have anticipated. We'll have to see ultimately if there's any adjustments made in the final rate notice, but we are anticipating that we will see a negative ultimate rate impact for 2024.
I would say all of that just reinforces for us, you know, the belief we've always had, that we need to migrate from a fee-for-service model to more of a value-based model broadly within home health. We certainly have the work that we continue to support on a, on a full value-based model, to support the Humana membership under a capitated model. We have a little over 800,000 members being supported by that model today, with the intent to get to 40% within a couple of years. We've also continued to expand sort of discrete capabilities, like, you know, managing-
Mm-hmm.
DME more broadly, and have nearly almost all of our individual MA members covered by that model today on the DME side. So we'll continue to take progress there, while the team also looks at ways to introduce value-based payment models and principles, even in the fee-for-service world. Whether that's through case rate, you know, payment models versus a, you know, pay-per-visit model, which then reinforces and aligns the incentives on really focusing on overall total cost of care and health outcomes, even in the fee-for-service space, while we continue to migrate the membership under a, a more traditional full value-based model. Underlying all of that is the need to really improve the clinical model, relative to what we see in the fee-for-service world today. So a lot of work continues to be done there.
It's still, I would say, early innings, a lot still to be learned about exactly what interventions are needed, what we need to bring to bear and what capabilities we need. But that continues to be an emphasis within Humana, so we can accelerate the value creation within the home health space.
And then within pharmacy, there's obviously a very dynamic period. There's a ton going on between, like, the IRA, Alzheimer's drugs, GLP-1, biosimilars. I guess, what is the company the most focused on in terms of managing through? I guess, like, what are the biggest opportunities for the company from, like, a growth perspective, maybe within CenterWell? And I guess, what are you watching the most closely when it comes to trend or medical costs on the health plan side of the business?
Yeah, there's really two sides to that. One is on the just the pharma side of the both the science and the changing and status of the drugs. And then the second is really in the payment mechanism that CMS has set up. Those two dynamics are really coming to a head over the next few years and is creating the complexity you're talking about. On the payment side, you know, we continue to see a very high orientation into lowering the cost of drugs. You see that in the negotiation drug negotiation concept of that. You see that in the area of moving more rebates or the DIR to the Rx counter, or taking it away-
Mm-hmm.
- to the maximum out-of-pocket being introduced, and then at 8,000, moving down to 2,000 in 2025. So you just see this orientation, how do you bring the drug cost down? And that's really in payment structure. What we did see this year is the... And the subsidy really is increasing, keeping premiums at a rate that is not gonna reflect all the changes.
Mm-hmm.
So the consumer is actually seeing some stabilization there. I think that what our estimate is that, like, subsidization is going from $1.50 PMPM to close to $30 PMPM, and we anticipate it getting up to $100 next year as a result of the maximum out-of-pocket expense changes. So you see that changing there, and but the customer isn't really feeling that change as much as they would, and they're seeing the benefit of the drug discount at the counter. The second part is in the area of both the science and you've mentioned a few of those.
We do see the introduction of biosimilars, you know, continuing to be an opportunity for the industry overall to lower lower costs with the early part of the introduction of Humira, and the biosimilar introduction really hasn't changed the market that much just because of the both the cost side of it hasn't really been reflected as much in it, and then secondarily, we also see providers and patients not wanting to upset the apple cart in their therapy. So we do see a more stable market, but we do anticipate in 2024, that that will continue to be an opportunity to lower the cost of the drug down. Ultimately being reflected in the premiums for the customer and bringing that down. Alzheimer's, we continue to see very little pickup there.
We've gotten a few, you know, approvals that have gone through, but we don't see a lot of pickup. But that's a disease that I think over time, we're going to see eventually the science take on, and we're going to have to, to-
Yeah
... you know, incorporate that in the cost of drugs and ultimately, the premiums, whether it's Part D or in Medicare Advantage area. So a lot changing, a lot of dollars moving around. I would say from a premium point of view, where some of this will be reflected in the premium, but the stabilization, the subsidy that is being provided, is keeping some of those premiums at a rate that's very manageable from a consumer point of view.
Okay. And then just thinking about the regulatory or the legislative backdrop, would love to get a sense of what you're focused on there. Like, when you're having conversations in D.C., what are you advocating for? And as we think about, you know, the rate cycle for the next couple of years, you know, in terms of known items, obviously, we have the phase-in of the risk model over the next couple of cycles. Do you feel like that creates, like, a little bit more stability, where that's obviously a disruptive change, but it's unlikely that there would be incremental changes layered on top of that? I guess, how's the company thinking about that?
Yeah, I would, I would say a few... There's really, a few areas where we are oriented to that we, we believe will be reflected in the regulatory side. Most of those are oriented to processes.
Mm-hmm.
We do believe pre-authorization will continue to be a focus, and, you know, taking friction out of the system, so to speak.
Yeah.
And we believe that's the right thing to do. We just need, you know, how it is implemented and the rules and all the connections, all the changes that are there. Is it, you know, manageable and both from a point of view of the provider and the payer side-
Mm-hmm
... side? So that's, that's an area where we, we know that there's gonna be continued active conversation with. We do believe marketing and just broker payments and just the sales side will continue to have increased regulation around it, and continue orientation to how to make it both more efficient, but in addition, make it much more less confusing for the customer. So we do see that as being-
Mm-hmm
... an area of orientation. On the rate side, you know, we've seen over the years a plus or minus, all the way from a +2 to a ±2, and I think we'll continue to stay in that range.
Mm-hmm.
Obviously, that's not pro forma for any of the risk adjustment side of it, but I think that's the range we're gonna see, and that it is manageable.
Mm-hmm.
And as we've, you know, said many times before, we've seen different administrations, you know, pick either side of that equation, but we do feel it's manageable.
Okay. And I guess the last question, as a quick update on RADV at the beginning of the year, it was all everyone was focused on. I think it kinda got quiet for a while when people saw some of the, you know, cost estimates coming out of CBO or coming out of the budgetary process-
Mm-hmm
... around that. Obviously, you guys are in the news a little bit last week there. Just get an update on how you guys have, are thinking about RADV as you've been able to spend more time on the issue?
Yeah, we can. Let's just maybe talk about our filing last week and just some perspective on that. We've been fairly vocal as the industry as not having a fee-for-service adjuster is a negative. That's not how the program was established. We wanted to understand the audit process. Not having the fee-for-service adjuster, we wanted to understand the audit process, and we've always been somewhat confused why the industry didn't have a chance to comment on the ultimate.
Mm-hmm
... notice that was given, because that's usually a traditional way to approach it. And as we've gone through since the announcement in the winter and really have had little engagement-
Mm-hmm
... and little understanding from the agency on how the audit process would work and some of those details, we just came to the conclusion that it's just there's a lot of unanswered questions, and we felt that it would be best to utilize legal means to get those questions answered because we didn't feel we were getting the questions answered in a way that was, you know, timely. And really, the audits will start soon, and we will have some retroactive risk there as they start moving into the 2018 audits.
All right. Well, thank you so much for your time.
Well, thank you.
I really appreciate all the insight.
Well, we're very timely. You finished right on time.
Yes, thanks.
Thank you.