The Association for Community Affiliated Plans (ACAP) greatly appreciates the opportunity to provide comments to the Centers for Medicare and Medicaid Services (CMS) in response to the Request for Comments: Enhancements to the Star Ratings for 2016 and Beyond. In October 2014, ACAP — along with several of our member plans — responded to CMS’ Request for Information regarding the impact that dual eligible populations have on a contract’s overall star rating. As we look ahead to 2016 and beyond, ACAP reiterates its support for a star ratings methodology that adjusts for dual eligible populations and ensures that plans are being evaluated for their performance, rather than the underlying health needs of their enrollee population.

ACAP is an association of 59 not-for-profit and community-based Safety Net Health Plans (SNHPs) located in 24 states. Our member plans provide coverage to over ten million individuals enrolled in Medicaid, Children’s Health Insurance Program (CHIP) and Medicare Special Needs Plans for dual-eligible beneficiaries. Nationally, ACAP plans serve approximately one-third of all Medicaid managed care enrollees, and 19 plans enroll D-SNPs. Close to 15 of our plans are Medicare-Medicaid Plans serving people in the financial alignment demonstrations.

The correct assessment of plans’ ability to serve the highly complex and disparate subpopulations of people enrolled in both Medicare and Medicaid, the dual-eligible beneficiaries, is a consumer as well as a plan issue. Dual-eligible beneficiaries lose when their plans do not receive accurate Star ratings and the accompanying bonus to share with their members in the form of supplemental benefits.



In its proposed methodology enhancements and changes, CMS highlights an array of proposed changes across different parts of the Medicare Advantage landscape. In this letter, ACAP will focus its attention only on those proposals and policy questions that are most likely to have an impact on the safety net health plans that provide care and coverage to people with limited income and/or status as a dual beneficiary. We reserve answers on some parts of the request until the opportunity provided in February with the 2016 Advanced Notice and Call Letter.

Development of an Integrated Star Rating system for Medicare-Medicaid Plans (MMPs)

This notices indicates that CMS is exploring the development of an integrated Star Rating system for Medicare-Medicaid Plans (MMPs) participating in the capitated financial alignment model. ACAP supports the development of a quality rating system specifically for plans which integrate care for people receiving both Medicare and Medicaid whether through MMP plans in the current demonstrations or through fully integrated D-SNPs. We urge CMS to take this opportunity to design a system which will sustain all integrated plans until a permanent model is developed after evaluation of the financial alignment demonstrations. We look forward to seeing more information as promised for the first quarter of 2015.

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