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Potential Areas for Comment on CMS Proposed Rule on Medicare Advantage for CY2025

Medicare Advantage (MA) dual eligible special needs plans (D-SNPs) are MA plans tailored specifically to the needs of people who are dually eligible for Medicare and Medicaid. In 2023, more than 5 million dually eligible beneficiaries receive their Medicare benefits and sometimes their Medicaid benefits through D-SNPs. Because of 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, D-SNPs are an area of focus for the Commission.

On November 15, 2023, the Centers for Medicare & Medicaid Services (CMS) published a notice of proposed rulemaking (NPRM) that would make technical changes to the MA and Medicare Part D programs for contract year 2025, including D-SNPs.

This presentation summarized provisions in the proposed rule that affect dually eligible beneficiaries and that overlap with the Commission’s work and areas for potential comment.  If the Commission chooses to comment, staff will develop a comment letter incorporating feedback from Commissioners.