The Centers for Medicare & Medicaid Services (CMS) in 2022 finalized rulemaking that ended the Financial Alignment Initiative (FAI), a demonstration program intended to test models that could increase financial alignment between Medicaid and Medicare while integrating primary care, acute care, behavioral health services, and long-term services and supports for dually eligible beneficiaries.
Several models were offered under the demonstration, but most participating states signed on to the Medicare-Medicaid Plan (MMP), a capitated model with a three-way contract between CMS, the state Medicaid agency, and the health plan. CMS allowed states to continue their demonstrations through the end of 2025 if they submitted tentative plans for transitioning their MMP populations to integrated dual-eligible special needs plans (D-SNPs), a Medicare Advantage product that only enrolls those who are dually eligible for Medicaid and Medicare and provides coverage according to a model of care. These plans also coordinate or cover Medicaid benefits.
Following the CMS decision to sunset the demonstrations, the Commission expressed an interest in monitoring the transition from the MMPs to D-SNPs, and in its June 2023 report to Congress, presented a framework for doing so. The framework focused on four key elements: stakeholder engagement, procurement, information technology (IT) system changes, and enrollment. Since that framework was published, staff have continued to monitor transition efforts across participating MMP states. Staff presented Commissioners with key findings on stakeholder engagement efforts related to the transition in December 2023 and with updates on procurement, IT system changes, and enrollment in April 2025.
In this presentation, staff provided Commissioners with updates on state procurement, IT system changes, enrollment processes, and stakeholder engagement, including communication with MMP enrollees.