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Comment Letter to CMS: Proposed Rule on Medicare Program and Revisions to Medicare Enrollment, Eligibility

In a letter to Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks LaSure, MACPAC commented on the following proposed rule: Medicare Program; Implementing Certain Provisions of the Consolidated Appropriations Act, 2021 and Other Revisions to Medicare Enrollment and Eligibility Rules, 87 Fed. Reg. 25090 (April 27, 2022).

Over the past several years, the Commission has engaged in many conversations related to coverage for individuals who are dually eligible for Medicaid and Medicare and has focused on policies to support states and promote integration of Medicaid and Medicare because of its potential to improve outcomes for beneficiaries and reduce spending. While the notice of proposed rulemaking is primarily focused on the implementation of certain provisions of the Consolidated Appropriations Act, 2021 (CAA, P.L. 116 260), it makes several changes that would affect state Medicaid programs and dually eligible beneficiaries.

In the letter, MACPAC notes that many of the policy changes in this proposed rule align with MACPAC’s interest in improving the beneficiary experience and reducing the burdens dually eligible beneficiaries face in navigating coverage under two programs. This includes a proposal to extend Medicare Savings Program coverage for individuals enrolled in the Medicare Part B immunosuppressive drug benefit, codifying a long-standing practice of making changes to a state’s buy-in policy through the Medicaid state plan, and limiting retroactive state liability for Medicare Part B premiums to 36 months.

In addition, the proposed rule would establish a new Medicare special enrollment period for individuals who lose Medicaid eligibility after the public health emergency ends. MACPAC supports CMS’ efforts to establish streamlined, seamless eligibility and enrollment processes across the continuum of programs for which individuals may qualify.