March 5, 2018

Liz Richter, Acting Principal Deputy Administrator
Centers for Medicare and Medicaid Services
Director, Center for Medicare
United States Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, D.C. 20201

Submitted via electronic submission system to CMS-2017-0163

Re: Advance Notice of Methodological Changes for Calendar Year (CY) 2019 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2019 Call Letter

Dear Ms. Richter:

The Association for Community Affiliated Plans (ACAP) greatly appreciates the opportunity to provide comments to the Centers for Medicare & Medicaid Services (CMS) on the 2019 Advanced Notice and Draft Call Letter. ACAP is an association of 61 not-for-profit, community-based Safety Net Health Plans located in 29 states. Our member plans provide coverage to over twenty million individuals enrolled in Medicaid, Children’s Health Insurance Program (CHIP) and Medicare Advantage Dual-Eligible SNPs. Nationally, ACAP plans serve approximately one-third of all Medicaid managed care enrollees. Twenty-three of our plans are D-SNPs and 14 of our plans participate in the Financial Alignment Demonstration.

Summary of ACAP’s Comments
Please find below a list of ACAP’s comments. ACAP has chosen to respond to a subset of proposals in the Advance Notice that are particularly relevant to Safety Net Health
Plans. We submit comments on the following areas: Changes to Risk Adjustment Methodology, SNP Specific Networks, Star Ratings and Social Risk Factors, Opioid
Utilization Standards, and Encounter Data.

The positions summarized below are explained in greater detail later in the letter.

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