In a letter to Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure, MACPAC commented on a proposed CMS rule on policy and technical changes to Medicare Advantage and Medicare Part D for Contract Year 2025. The proposed rule would make a number of changes affecting beneficiaries who are dually eligible for Medicaid and Medicare.
The Commission’s long-term vision is that all dually eligible beneficiaries should have access to integrated care. States are at different stages of integrating coverage for dually eligible beneficiaries, and the availability of integrated models as well as the level of integration offered in those models varies. In June 2022, the Commission recommended that all states develop an integrated care strategy. To support states in developing their strategies and raising the bar on integrated care, the Commission also recommended that Congress provide additional federal funding to states to assist them in their efforts (MACPAC 2022).
Medicare Advantage (MA) plans become dual eligible special needs plans (D-SNPs) are an area of focus for the Commission given their widespread availability, the number of dually eligible beneficiaries enrolled in them, and the requirement that D-SNPs contract with the state Medicaid agencies in which they operate. We applaud CMS for seeking to ensure D-SNPs are a meaningful vehicle for integration and our work in this area lends itself to commenting on several of the proposed changes in the rule. Our comments in this letter draw on our work in this area, including relevant recommendations.