The Association for Community Affiliated Plans (ACAP) greatly appreciates the opportunity to provide comments to the Centers for Medicare and Medicaid Services (CMS) in response to the Advance Notice of Methodological Changes for Calendar Year (CY) 2016 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2016 Call Letter. Overall, we are concerned that a number of proposals in the advance notice and draft call letter will exacerbate existing under payments for highcost beneficiaries and will further disadvantage D-SNPs and their enrollees.
ACAP is an association of 58 not-for-profit, community-based Safety Net Health Plans located in 24 states. Our member plans provide coverage to over ten million individuals enrolled in Medicaid, Children’s Health Insurance Program (CHIP) and Medicare Advantage Dual-Eligible Special Needs Plans. Nationally, ACAP plans serve approximately one-third of all Medicaid managed care enrollees. Eighteen of our plans are D-SNPs that cover LTSS or behavioral health services (to the extent permitted by state plan amendments or state law). Fourteen of our plans participate in the financial alignment demonstration. Collectively these 14 ACAP plans account for over 30 percent of all enrollment in the financial alignment demonstration.