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 Information Regarding Data on Differences in Medicare Advantage (MA) and Part D Star Rating Quality Measurements for DualEligible versus Non-Dual-Eligible Enrollees. In the past, ACAP has called on CMS to reevaluate its reimbursement structure to accurately account for the underlying characteristics of a plan’s enrollees. We believe that the stars quality rating system, in its current form, disadvantages health plans that enroll full-benefit dual eligible populations, and we applaud CMS for issuing this RFI to gather more information on this important subject.

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.

ACAP appreciates CMS’ acknowledgement of the work of the National Quality Forum (NQF) about the impact of socioeconomic status on quality ratings and we urge adoption of their overall recommendations. (


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