In this letter to Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma, MACPAC comments on a number of proposals in CMS’s February 2020 proposed rule on Medicare Advantage (MA) plans that would affect plans serving beneficiaries who are dually eligible for Medicaid and Medicare.
In the Commission’s view, increasing the availability of integrated care programs such as those available through dual-eligible special needs plans (D-SNPs) could improve beneficiary care and promote coordination between Medicaid and Medicare. D-SNP look-alike plans—traditional MA plans that market to dually eligible individuals but do not offer integrated care—work against state and federal efforts to promote integration by drawing beneficiaries away from integrated models.
In its comments, the Commission observes that CMS’s proposal to stop contracting with D-SNP look-alike plans where dually eligible beneficiaries represent 80 percent or more of enrollment is a good starting point. However, the Commission suggests that the agency may need to further reduce this threshold if evidence shows that look-alike plans with lower enrollment levels are siphoning off enrollment in integrated care programs. The Commission also addresses CMS’s proposed changes to network adequacy, calling them a move in the right direction, as well as proposals in the rule aiming to improve care management and expand benefits for beneficiaries with chronic disease.
Finally, the letter summarizes a MACPAC analysis of D-SNP look-alike availability and stakeholder interviews that informed the Commission’s comments on the CMS proposals.