ACAP 2017 Transformation Ideas per 2018 Announcement of Rates

April 19th, 2017
Seema Verma, Administrator
Centers for Medicare and Medicaid Services
United States Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, D.C. 20201
Submitted via e-mail to:

Re: 2017 Transformation Ideas per CMS’ Request for Information
Dear Ms. Verma,
The Association for Community Affiliated Plans (ACAP) greatly appreciates the opportunity to provide comments to the Centers for Medicare & Medicaid Services (CMS) on the Request for Information in the 2018 Announcement of Rates and Final Call Letter.
ACAP is an association of 60 not-for-profit, community-based Safety Net Health Plans located in 28 states. Our member plans provide coverage to over seventeen million individuals enrolled in Medicaid, Children’s Health Insurance Program (CHIP) and Medicare Advantage Dual-Eligible SNPs (D-SNPs). Nationally, ACAP plans serve approximately one-third of all Medicaid managed care enrollees. Twenty-four of our plans are D-SNPs and 14 of our plans participate in the Financial Alignment Demonstration, collectively enrolling over one-third of all enrollees in the Demonstration.
Please find below ACAP’s comments on ways that CMS can improve flexibility, efficiency, and promote innovation in the Medicare Advantage program. These comments are driven by the experience of ACAP’s D-SNPs and MMPs in providing care to high-need and high-cost dual-eligible beneficiaries.


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