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A Letter to the CMS on Medicare Advantage Plan Rules

In a formal letter to the Centers for Medicare and Medicaid Services, we call for the agency to stop Medicare Advantage plans from inappropriately targeting vulnerable individuals that are dually eligible for Medicare and Medicaid.

In response to a proposed regulation released from the Centers for Medicare and Medicaid Services (CMS) earlier this year, Arnold Ventures urges the administration to use its authority to prevent plans that are marketed to dual-eligible beneficiaries but don’t provide the coordinated coverage necessary to integrate care.

Understanding Medicare coverage options is challenging enough, but dual eligible beneficiaries must enroll in and navigate both Medicare and Medicaid coverage, oftentimes while managing multiple complex and chronic conditions. To ease these challenges, lawmakers have built special types of Medicare Advantage plans called Dual Eligible Special Needs Plans (D-SNPs). However, as the number of D-SNPs has increased, so too have look-alike or imposter plans.

This can be confusing to beneficiaries, leaving them to navigate a maze of different coverage and administrative requirements. CMS proposes in a rule released earlier this year to crack down on this practice and limit the availability of these plans.

We are supportive of this action but we think CMS needs to go further to prevent these plans and promote integration between Medicare and Medicaid.

Read the full letter: