In this letter to Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma, MACPAC comments on a November 1, 2018 proposed rule that would, among other changes, implement new requirements to integrate Medicare and Medicaid benefits in Medicare Advantage dual eligible special needs plans (D-SNPs) and unify grievance and appeals procedures for D-SNP enrollees.
In its letter, the Commission observes that the proposed rule is generally aligned with the Commission’s interest in integration as a tool to improve care for dually eligible beneficiaries and potentially reduce costs, and supports the proposed approach to strengthening the D-SNP model of integrated care and unifying grievance and appeals procedures for D-SNP enrollees. However, the Commission notes that as states make selective contracting decisions—in some cases to align D-SNPs with Medicaid managed care—managed care organizations may choose to create D-SNP look-alike plans when they are unable to secure state contracts. The Commission urges continued monitoring of look-alike plans, to identify their potential effects on integration efforts and determine if further action needs to be taken either by CMS or Congress.
