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Comment Letter: Proposed Rule on Policy and Technical Changes to Medicare Advantage and Medicare Part D for Contract Year 2024

In a letter to the Centers for Medicare & Medicaid Services (CMS), MACPAC commented on the proposed rule changes for the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, and other programs.

The proposed rule changes by CMS include closing loopholes for dual eligible special needs plan (D-SNP) look-alike plans, expanding language access, protecting beneficiaries from misleading marketing, increasing access to coverage of Medicare Part D premiums, and closing gaps in prescription drug coverage for Medicaid beneficiaries. Overall, MACPAC supports the proposed rule changes by CMS and believes they will aid in the Commission’s goal of integrating care for dually eligible beneficiaries and improving their experience.

The Commission supports CMS’s move to close loopholes for D-SNP look-alike plans, but remains concerned that these types of plans may still persist. The Commission suggests that CMS continues to monitor the situation to prevent growth in D-SNP look-alike plans. The Commission supports the proposed changes to language access and marketing practices, as they aim to improve equity and prevent confusion among dual eligible beneficiaries. The Commission also supports the expansion of the Low-Income Subsidy (LIS) program’s eligibility from 135 percent of the federal poverty level to 150 percent. Lastly, the Commission supports changes in the proposed rule that would establish the Limited Income Newly Eligible Transition program as a permanent program. The proposed change would help certain low-income Medicaid beneficiaries avoid potential gaps in their prescription drug coverage and improve access to care.