In a letter to Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure, the Medicaid and CHIP Payment and Access Commission commented on CMS’s proposed rule: Medicare Program; Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs, 87 Fed. Reg. 1842 (January 12, 2022).
Over the past several years, the Commission has engaged in many conversations regarding integrated care programs for individuals who are dually eligible for Medicaid and Medicare. Our work has focused on three goals: increasing enrollment in integrated products, making integrated products more widely available, and promoting greater integration in existing products.
The Commission discussed this proposed rule at our January 20, 2022 public meeting. The Commission generally supports the changes intended to promote integration of care for dually eligible beneficiaries by applying features of the Medicare-Medicaid plans (MMPs) operating under the Financial Alignment Initiative to Medicare Advantage (MA) dual eligible special needs plans (D-SNPs). However, the proposed rule addresses only one of our three goals of integrated care; it does not necessarily increase the availability of integrated models or enrollment in integrated plans.
The letter urged CMS to look for ways to expand policies to promote integration beyond D-SNPs with exclusively aligned enrollment (plans where the same entity is responsible for all Medicaid and Medicare benefits for its members) so that more beneficiaries have access to them. MACPAC also outlined concerns about a proposed transition for states to convert their MMPs to D-SNPs if the provisions of the proposed rule are finalized. Certain aspects of integrated coverage may be hard to replicate in D-SNPs and should be considerations for future rulemaking, including a shared savings mechanism for states. Finally, MACPAC highlighted some of the proposed changes affecting dually eligible beneficiaries and offered comments.
