ACAP Comment Letter on D-SNP Integration Requirements

April 11, 2018

Tim Engelhardt
Centers for Medicare and Medicaid Services
Director, Medicare-Medicaid Coordination Office
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

Re: Request for Stakeholder Input: Implementing the Dual Eligible Special Needs Plans (DSNPs) Provisions of the Bipartisan Budget Act of 2018 (Public Law No. 115-123)

Dear Mr. Engelhardt:

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 Stakeholder Input on Implementing the D-SNP provisions of the Bipartisan Budget Act (BBA) of 2018. 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. Twenty-three of our plans are D-SNPs, twenty-three operate Managed Long-Term Care Supports and Services (MLTSS) plans, and 14 of our plans participate in the Financial Alignment Demonstration.

We submit the following comments for CMS’ consideration:

Overarching Comments

ACAP encourages CMS to adopt flexibility as a guiding principle when developing the D-SNP requirements for integration and the uniform appeals and grievances processes. The D-SNP integration requirements should be flexible enough to account for: (1) state variation in the delivery of LTSS and behavioral health programs; (2) state progress towards Medicare and Medicaid integration in the future, including incremental steps toward integration; and (3) integration activities at the plan level for all types of D-SNPs, i.e., those that are FIDE-SNPs, operate under the parent organization model, coordinate with a separate MLTSS plan, or coordinate with fee-for-service for LTSS or behavioral health services.

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