CMS Medicare Guidance, Rulemaking, and Public Comments

Updated Guidance for Medicare Advantage Organizations

This memo provides answers to questions related to two CMS memos released on April 21 and April 23 for Medicare Advantage and Part D plans (including D-SNPs and Medicare-Medicaid Plans (MMPs)) describing guidance for plans related to the COVID-19 pandemic. This guidance contains several points of potential interest for states with integrated care initiatives.

CMS Updates Processes for D-SNPs Implementing CY 2021 Medicare-Medicaid Integration and Unified Appeals and Grievance Requirements in Response to COVID-19: Clarification on Direct Contracts with States

Centers for Medicare & Medicaid Services (CMS) issued a memo detailing important updates on CMS processes for review and approval of state Medicaid agency contracts (SMACs) for contract year 2021. These updates acknowledge the unique circumstances resulting from Dual Eligible Special Needs Plans’ (D-SNPs’) and states’ priority focus on the COVID-19 public health emergency.

Spotlight: New Interoperability and Patient Access Rule Will Affect Dually Eligible Individuals

On March 9, the Centers for Medicare & Medicaid Services (CMS) issued the Interoperability and Patient Access final rule (CMS-9115-F), which is designed to improve patient access to their health information, improve interoperability and encourage innovation, while reducing burden on payers and providers. Two provisions will specifically affect dually eligible individuals (see Section VII, Improving the Medicare-Medicaid Dually Eligible Experience by Increasing the Frequency of Federal-State Data Exchanges, and final changes to regulatory text in Parts 406, 407, and 423).

Updated CMS Processes for Dual Eligible Special Needs Plan (D-SNP) Implementing CY 2021 Medicare-Medicaid Integration and Unified Appeals and Grievance Requirements in Response to Coronavirus Disease 2019 (COVID-19)

In response to the unique circumstances resulting from D-SNPs’ and states’ priority focus on reducing the risks of COVID-19 transmission and maintaining continuity of operations, this memorandum outlines updated CMS processes for review and approval of state Medicaid agency contracts (SMACs) for contract year 2021. The goal is to provide D-SNPs and states with as much additional time as possible to execute contracts consistent with these new regulatory requirements prior to the January 1, 2021, effective date.

CMS Invites Comments on Proposed Rule for Medicare Advantage and Part D

On February 5, 2019, the Centers for Medicare & Medicaid Services (CMS) posted a new notice of proposed rulemaking for Medicare Advantage and Part D (see also the accompanying fact sheet). CMS also released the Advance Notice Part II and fact sheet). This e-alert includes notable provisions of the proposed rule and advanced notice.

Integrated Care Updates - January 2020

January 2020 Contents:

  • New ICRC Flow Charts Compare Existing and New Unified Appeals and Grievance Processes for Individuals Enrolled in Applicable Integrated D-SNPs
  • CMS Releases Additional Guidance on D-SNP Integration Requirements
  • CMS Releases the 2021 Medicare Advantage Advance Notice
  • MACPAC Considers Policy Options to Better Integrate Care for Dually Eligible Individuals
  • January 2020 Enrollment in Medicare-Medicaid Plans 
  • January 2020 Enrollment in PACE Organizations 
  • Key Upcoming Dates