August 13, 2018
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 MMCOCapsmodel@cms.hhs.gov
Re: Proposed Update to MMP Medicare A/B Rate Methodology for CY 2019
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 proposed update to MMP Medicare A/B rate methodology for CY 2019. 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-two of our member plans are D-SNPs, twenty-three operate Managed Long-Term Care Supports and Services (MLTSS) plans, and 13 of our member plans participate in the Financial Alignment Demonstration.
We share in the Administration’s desire to arrive at fair and accurate payments to plans serving dual-eligible beneficiaries. As CMS is aware, it has been a struggle to develop accurate payments for MMPs during the demonstration. Dual eligibles tend to be costlier to treat upon enrollment
in an MMP due to unmet need and the effects of non-integrated or coordinated care. CMS has taken steps to improve payment adequacy for MMPs in recent years with the implementation of the six segment CMS-HCC risk-adjustment model for all MMPs and the application of the frailty adjuster in NY.