November 16, 2018
Assistant Secretary for Planning and Evaluation
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 ASPEImpactStudy@hhs.gov
Re: IMPACT ACT Research Study: Provider and health plan approaches to improve care for Medicare beneficiaries with social risk factors
The Association for Community Affiliated Plans (ACAP) greatly appreciates the opportunity to provide comments to Assistant Secretary for Planning and Evaluation (ASPE) on the IMPACT ACT Research Study: Provider and health plan approaches to improve care for Medicare beneficiaries with social risk factors. ACAP is an association of 63 not-for-profit, community-based Safety Net Health Plans located in 29 states. Our member plans provide coverage to over twenty-one million individuals enrolled in Medicaid, Children’s Health Insurance Program (CHIP) and Medicare Advantage Dual-Eligible SNPs. Twenty-three of our member plans are D-SNPs, twentythree operate Managed Long-Term Care Supports and Services (MLTSS) plans, 13 of our member plans participate in the Financial Alignment Demonstration, and our plans make up thirty-three percent of all Medicare-Medicaid plans’ enrollment.
ACAP plans have developed several initiatives to address social risk factors prevalent in their communities by working with states and community-based organizations. These initiatives have improved beneficiaries’ health outcomes and demonstrated long-term cost savings. The dual eligible
beneficiaries our plans serve are most at risk due to their socioeconomic status. Below includes details of our plans initiatives and our comments in response the questions posed in the RFI.