May 25, 2018

Seema Verma, Administrator
Centers for Medicare and Medicaid Services
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 on Direct Provider Contracting Models

Dear Ms. Verma:
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 Information on Direct Provider Contracting Models. ACAP is an association of 61 not-for-profit, community-based Safety Net Health Plans located in 29 states, some of whom are provider-owned. 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 fourteen of our plans participate in the Financial Alignment Demonstration.

We submit the following comments for CMS’ consideration:

Overarching Comments

Managed Care Organizations (MCOs) are important partners with CMS and states in the provision of Medicare and Medicaid benefits. ACAP’s member plans manage and coordinate Medicare and Medicaid services, improve quality of care, assume two-sided financial risk, improve the delivery system through value-based purchasing arrangements, integrate physical and behavioral health services, and address social determinants of health. The following three points summarize the value MCOs bring to the Medicare and Medicaid programs:
Equipped to manage benefits and accept financial risk with reserves
Extra benefits and care management available to enrollees
Established partners of CMS and states

ACAP-member plans are partners with providers and CMS in improving the delivery of Medicare and Medicaid benefits. ACAP plans work closely with providers in their communities to improve care delivery, care coordination, and quality of care. For example, many ACAP members are

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