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RFI on Data and Recommendations to Improve Care for Dually Eligible Beneficiaries

In response to a request for information (RFI) from Congress on recommendations to improve care for dually eligible beneficiaries, MACPAC offered comments in three areas providing evidence-based findings and recommendations on policy issues that overlap with the questions in the RFI: requiring state strategies to integrate care; state capacity to integrate care; and considerations for a new, unified program for dually eligible beneficiaries.

MACPAC’s longstanding view is that integrating care can improve the beneficiary experience and reduce federal and state spending that may arise from duplication of services or poor care coordination.

In our June 2022 report to Congress, MACPAC recommended that Congress authorize the Secretary of the U.S. Department of Health and Human Services to require that each state develop an integrated care strategy for full-benefit dually eligible beneficiaries. Developing a strategy, with support from the federal government, is a feasible first step for all states that could help raise the bar on integrated care. States are at varying stages of integrating Medicare and Medicaid coverage for dually eligible beneficiaries, operating on a continuum of integration, which may reflect variations in state capacity and competing priorities. To assist states in raising the bar on integrated care, MACPAC highlighted existing strategies states can use to increase integration in their contracts with Medicare Advantage dual eligible special needs plans.

In its letter, MACPAC also discussed the possibility of creating a unified program designed specifically for the dually eligible population to address the fragmentation of care and poor outcomes for beneficiaries that result from having two uncoordinated programs. A unified program could simplify coverage for beneficiaries and potentially decrease beneficiary and provider fragmentation and confusion, align incentives, eliminate cost shifting between Medicare and Medicaid, and fill existing gaps in coverage.

MACPAC highlighted three high-level considerations for establishing a unified program: (1) defining program goals, (2) deciding how the program would be administered, and (3) maintaining state flexibility.