Dual Eligible Special Needs Plans (D-SNPs)

Integrated Care Updates - March 2020

March 2020 Update Content:

  • CMS Corona Virus (COVID-19) Partner Toolkit and Electronic Mailing List
  • Dual Eligible Special Needs Plans (D-SNPs) Entries and Departures
  • MedPAC March Report to the Congress: Issues Related to Integrated Care
  • Key 2020 Medicare Dates
  • March 2020 Enrollment in Medicare-Medicaid Plans
  • March 2020 Enrollment in PACE Organizations
  • New Resources on the ICRC Website

Reprioritization of PACE, Medicare Parts C and D Program, and Risk Adjustment Data Validation (RACV) Audit Activities

In response to the spread of COVID-19, the Centers for Medicare & Medicaid Services (CMS) has suspended non-emergency federal and state survey agency surveys. Consistent with that action, CMS is reprioritizing scheduled program audits for Medicare Advantage organizations, Part D sponsors, Medicare-Medicaid Plans, and PACE oganizations. Oversight will continue but will shift to prioritize the investigation and resolution of instances of noncompliance where the health and/or safety of beneficiaries is at risk and complaints allenging infection control concerns.

CMS Invites Comments on Proposed Rule for Medicare Advantage and Part D

On February 5, 2019, the Centers for Medicare & Medicaid Services (CMS) posted a new notice of proposed rulemaking for Medicare Advantage and Part D (see also the accompanying fact sheet). CMS also released the Advance Notice Part II and fact sheet). This e-alert includes notable provisions of the proposed rule and advanced notice.

Integrated Care Updates - January 2020

January 2020 Contents:

  • New ICRC Flow Charts Compare Existing and New Unified Appeals and Grievance Processes for Individuals Enrolled in Applicable Integrated D-SNPs
  • CMS Releases Additional Guidance on D-SNP Integration Requirements
  • CMS Releases the 2021 Medicare Advantage Advance Notice
  • MACPAC Considers Policy Options to Better Integrate Care for Dually Eligible Individuals
  • January 2020 Enrollment in Medicare-Medicaid Plans 
  • January 2020 Enrollment in PACE Organizations 
  • Key Upcoming Dates

Additional Guidance on CY 2021 Medicare-Medicaid Integration Requirements for Dual Eligible Special Needs Plans (D-SNPs)

This HPMS memo provides additional guidance and clarification on four topics related to new integration standards for Dual Eligible Special Needs Plans: (1) distinctions between fully integrated D-SNPs (FIDE SNPs) and highly integrated (HIDE SNPs); (2) permissibility of carve-outs of behavioral health services and long term services and supports (LTSS) for FIDE SNPs and HIDE SNPs; (3) alignment of D-SNP and companion Medicaid plan service areas; and (4) compliance with integration requirements for D-SNPs that only enroll partial-benefit dually eligible individuals.

Appeals and Grievances: Comparisons of Existing and New Integrated Processes for Individuals Enrolled in Applicable Integrated Plans

Beginning in 2021, Dual Eligible Special Needs Plans (D-SNPs) with exclusively aligned enrollment must begin using integrated appeals and grievance processes. The flowcharts in this resource are designed to help states, health plans, and other stakeholders understand the differences between existing Medicare and Medicaid appeal and grievance processes and the new integrated appeal and grievance processes established at 42 CFR Part 422 Subpart M for fully and highly integrated D-SNPs with exclusively aligned enrollment.