IRVING, Texas, August 24, 2022 – Today, Vizient, Inc. offered comments in response to the Centers for Medicare and Medicaid Services’ (CMS) Request for Information (RFI) on the Medicare Advantage (MA) Program. In our comments, Vizient shared feedback on opportunities to strengthen the MA program and encouraged the agency to consider policies that would promote health equity, access to quality care, and affordable and sustainable healthcare.

To better ensure that all MA enrollees receive the care they need, Vizient recommended that CMS improve MA plan communications, utilize validated and standardized screening tools to support health equity, and consider using indices developed specifically to help address health inequities, such as the Vizient Vulnerability Index™ (VVI), for measurement efforts. Vizient also encouraged CMS to take immediate steps to improve the prior authorization (PA) process and other utilization management techniques to mitigate disruption to patient care and significant administrative burden and workload, among other issues.

Additionally, Vizient shared key survey insights that highlight the detrimental effects of plan-mandated white bagging policies on patients and providers, and encouraged CMS to address the barriers to affordable and sustainable care.

“Vizient members continue to make clear that white bagging practices and onerous prior authorization requirements risk patient safety and cause unnecessary operational burden,” said Shoshana Krilow, senior vice president of public policy and government relations for Vizient. “Vizient encourages CMS to consider the implications of these payer-mandated policies on providers and patients to ensure care is not compromised.”

Vizient appreciates the agency’s efforts to work with stakeholders on MA policy development and welcomes the opportunity to further engage with CMS on various aspects of the program that impact our members.

About Vizient, Inc.

Vizient, Inc., the nation’s largest health care performance improvement company, serves more than 50% of the nation’s acute care providers, which includes 97% of the nation’s academic medical centers, and more than 20% of ambulatory care providers. Vizient provides expertise, analytics and advisory services, as well as a contract portfolio that represents more than $130 billion in annual purchasing volume. Vizient’s solutions and services improve the delivery of high-value care by aligning cost, quality and market performance. Headquartered in Irving, Texas, Vizient has offices throughout the United States. Learn more at