ACAP’s MLTSS Policy Priorities
1. CMS should conduct adequate oversight over MLTSS programs.
a. Provider networks—Give states more guidance on what constitutes an adequate MLTSS
network. The number and type of providers in a network, and time and distance standards
should be realistic and attainable.
b. Quality measurement—Give guidance to states to use appropriate MLTSS measures that
reflect the services that MLTSS plans cover.
c. Documentation and assessments—Work with states to streamline required documentation
and assessments for MLTSS plans and across MLTSS plans and LTSS providers.
d. Medicare data—Support the development of real-time, state-based, central repositories of
Medicare utilization data for dual-eligible beneficiaries to permit better coordination
between MLTSS and Medicare FFS.
2. CMS should work with states to ensure that managed care rates are adequate and actuarially sound for all LTSS enrollees.
a. Rate-setting should be as transparent as possible with transparency extended to the ratesetting
interactions between states and plans. States should be required to disclose
sufficient rate setting and actuarial soundness in a timely manner.
3. States should be allowed to implement Medicaid Managed Care for duals through State Plan Amendments.
a. Change the Medicaid law to allow states to implement Medicaid managed care in their
state, including for dual-eligible, via the more efficient state plan amendment (SPA)
process. Using the SPA process, instead of the current waiver process, will maintain a
strong level of federal oversight and input while giving states the flexibility to better
serve their enrollees.
4. CMS should be aware of other barriers to coordinating LTSS services and consider engaging states, plans, and other federal partners on these issues:
a. Housing— Give plans more flexibility to use Medicaid funds to cover housing assistance
services. Lack of access to housing is one of the biggest barriers to rebalancing between
institutional and community-based LTSS. Some MLTSS enrollees residing in nursing
facilities would be able to live safely in the community if they had access to affordable
b. Workforce—In some states, there is a shortage of Personal Care Attendants (PCA), in
part due to low PCA wages. PCAs could also benefit from better training on topics such
as how to identify a change in health status and how to work with managed care plans.