MACPAC submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) in response to proposed rulemaking on policy and technical changes to Medicare Advantage for Contract Year 2027. Medicare Advantage (MA) dual eligible special needs plans (D-SNPs) have been a particular area of focus for the Commission, given their widespread availability, the number of dually eligible beneficiaries enrolled in them, and the requirement that D-SNPs contract with the state Medicaid agencies in which they operate.
In the letter, MACPAC comments on several proposed rule changes affecting dually eligible beneficiaries, including updates and amendments to previously finalized D-SNP regulations. The proposed rule includes a request for information (RFI) on an area of interest to the Commission: that of increased enrollment among dually eligible beneficiaries in chronic condition special needs plans and institutional special needs plans, MA plans that do not offer integrated care. In the RFI, CMS requests comment on potential policy changes to support integrated care among this population. MACPAC has prior work relevant to several of the suggested policies, including state use of state Medicaid agency contracts, the importance of care coordination, and concerns about D-SNP look-alike plans.