About 3 million dually eligible beneficiaries are enrolled in Medicare Advantage (MA) dual eligible special needs plans (D-SNPs), which are present in 43 states. Most D-SNPs only meet the basic requirements to coordinate care, providing minimal integration of the Medicare and Medicaid programs. This presentation focused on a notice of proposed rulemaking from the Centers for Medicare & Medicaid Services (CMS) that would revise MA and Medicare Part D regulations, including regulations governing D-SNPs. One of CMS’s stated purposes for the proposed rule is improving integration of Medicaid and Medicare coverage for people enrolled in those plans. Medicare-Medicaid plans (MMPs), established under the Financial Alignment Initiative, are prominent in the proposed rule. CMS proposes that a number of MMP features be applied to D-SNPs. If the proposed rule becomes final, CMS suggests that MMPs convert to D-SNPs.
This presentation focused on areas for Commissioners to consider for potential comment. Next steps for staff include incorporating feedback from the discussion and drafting a comment letter.