September 28, 2023
The Honorable Chiquita Brooks-LaSure
Centers for Medicare and Medicaid Services
U.S. Department of Health and Human Services
200 Independence Avenue SW Washington, DC 20201
RE: Suggested Improvements to Medicare Plan Finder
Dear Administrator Brooks-LaSure:
The Association for Community Affiliated Plans (ACAP) is a national trade association representing 80 not-for-profit Safety Net Health Plans. Collectively, ACAP plans serve more than 25 million people enrolled in Medicaid, Medicare, the Marketplaces, and other publicly supported coverage programs. More than half of our member plans are D-SNPs, with the majority operating fully-integrated or highly-integrated D-SNPs (FIDE and HIDE SNPs, respectfully). Our mission is to support our member plans’ efforts to improve the health and well-being of people with low incomes and with significant health care needs. ACAP appreciates all the work that CMS has done, and continues to do, to improve care for dually eligible beneficiaries. In particular, the agency has taken great strides to improve Medicare and Medicaid integration through D-SNPs.
As you know, educating beneficiaries on their choices for Medicare coverage can be challenging. Moreover, the benefits of integrated and coordinated care through D-SNPs can be abstract and difficult for beneficiaries to understand. Medicare Plan Finder is an important tool for beneficiary education. Plan Finder can help dually eligible beneficiaries and their caregivers understand and differentiate between their options.
There are several areas where we feel that Medicare Plan Finder does not fully or clearly explain the benefits offered through D-SNPs. Additionally, some information on Medicare Plan Finder can be misleading, furthering beneficiary confusion. In this letter, we respectfully outline our concerns with Medicare Plan Finder and offer suggestions for improvements. We offer these recommendations in the hopes that CMS will consider them for changes to Medicare Plan Finder for the 2025 plan year and beyond.
Additional information and clarity are needed on which supplemental benefits are offered through D-SNPs
As CMS is aware, certain benefits – such as vision, dental, hearing and transportation services – are available to dually eligible beneficiaries through Medicaid. At times, a D-SNP will not offer one of these services as a Medicare Advantage (MA) supplemental benefit, because these services are available to their dually eligible enrollees through Medicaid, and the D-SNP can coordinate their dually eligible enrollees’ access to those Medicaid benefits. However, on Medicare Plan Finder, these benefits show up as a red X because they are offered through Medicaid rather than as an MA supplemental benefit. We feel this is unintentionally misleading to the beneficiary, as this suggests to the beneficiary that they will receive fewer benefits from a D-SNP, when they have access to those benefits through Medicaid. Moreover, when beneficiaries filter Medicare Plan Finder by type of supplemental benefit, the D-SNP will not show up as an option.
To better explain the comprehensive set of benefits offered to dually eligible beneficiaries through D-SNPs, as well as the benefit of receiving care coordination, we recommend that CMS change the red X for these benefits to either a green check mark or to a different icon (such as an orange circle). If using a different icon, the Plan Finder legend for the new icon should be clearly visible to the beneficiary and should clearly explain that these benefits are available to the dually eligible beneficiary through Medicaid. Additionally, when a dually eligible beneficiary filters plan finder by type of supplemental benefit, the D-SNP along with the new icon should show up in the search results along with the green check marks.
With respect to operationalizing this recommendation, we suggest that CMS change the D-SNP Plan Benefit Package (PBP) reports to enable D-SNPs to indicate which supplemental benefits they do not offer because those benefits are offered to their enrollees through Medicaid. This information could also be gained directly from State Medicaid data, however the PBP reports might be a timelier source of this information.
Display D-SNPs First on Plan Finder Search Results
Beneficiaries may have dozens of MA plan options depending on where they live. If they are unaware that they are eligible for integrated care, it may be difficult for the beneficiary to comb through the search results to see the D-SNP option and to understand that the D-SNP is the option for integrated care. To remedy this, we recommend that D-SNPs appear as the first Medicare Plan Finder search results for dually eligible beneficiaries. To make the distinction clearer and more obvious, D-SNPs could appear in a separate box or as a visually distinct search result segment that indicates that the following plans are the beneficiary’s options for integrated Medicare and Medicaid benefits. The order of D-SNPs presented could be as follows: FIDE SNPs first, followed by HIDE SNPs, and then Coordination-Only D-SNPs. Additionally, Plan Finder would need to include explanations for the beneficiaries on the differences between these D-SNP plan types. We recommend that a beneficiary’s D-SNP options always appear first on Plan Finder search results, including when the beneficiary has sorted the Plan Finder results, so that the beneficiary is always aware of their options for Medicare and Medicaid integration.
Clarify Medicaid Coverage of the Part B Premium
Medicaid covers the cost of the Part B premium for most dually eligible beneficiaries (generally, only beneficiaries eligible under the Qualified Disabled and Working Individuals – or QDWI program – do not receive Medicaid coverage of Part B premiums). However, the Medicare Plan Finder search results for all plans, including D-SNPs, say that the plan’s out-of-pocket cost sharing does not include the Part B premium. This is unintentionally misleading for dually eligible beneficiaries, as it leads them to believe that they will have to pay the Part B premium themselves if they enroll in a D-SNP or any other MA plan. We recommend that CMS remedy this so as not to confuse beneficiaries about the true extent of their out-of-pocket costs. For example, a sentence could be added to the Medicare Plan Finder language on Part B out-of-pocket costs that says that Medicaid covers the Part B premium for most people who are also eligible for Medicaid. If it is not possible to implement this change for all MA plan results on Plan Finder, then the change should be made at least to the Plan Finder descriptions of D-SNPs.
Add More Information Describing a D-SNP
Currently, Medicare Plan Finder describes a D-SNP by saying “This plan is designed for beneficiaries with Medicare and Medicaid.” We feel that additional information is needed to explain D-SNPs to beneficiaries and their caregivers. To this end, we recommend revising the sentence to “This plan is designed to coordinate coverage for beneficiaries with Medicare and Medicaid.” We also recommend adding another few sentences to this language to explain that beneficiaries with both Medicare and Medicaid coverage can receive all their Medicare benefits and some or all of the Medicaid benefits through the D-SNP.
We thank you for your time and attention to this issue. If you have any questions regarding the above comments, please do not hesitate to reach out to Christine Aguiar Lynch, Vice President of Medicare and MLTSS Policy (email@example.com).
Margaret A. Murray
Chief Executive Officer
Association for Community Affiliated Plans