Other Resource

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.

Reprioritization of PACE, Medicare Parts C and D Program, and Risk Adjustment Data Validation (RACV) Audit Activities

In response to the spread of COVID-19, the Centers for Medicare & Medicaid Services (CMS) has suspended non-emergency federal and state survey agency surveys. Consistent with that action, CMS is reprioritizing scheduled program audits for Medicare Advantage organizations, Part D sponsors, Medicare-Medicaid Plans, and PACE oganizations. Oversight will continue but will shift to prioritize the investigation and resolution of instances of noncompliance where the health and/or safety of beneficiaries is at risk and complaints allenging infection control concerns.

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.

Additional Guidance on CY 2021 Medicare-Medicaid Integration Requirements for Dual Eligible Special Needs Plans (D-SNPs)

This HPMS memo provides additional guidance and clarification on four topics related to new integration standards for Dual Eligible Special Needs Plans: (1) distinctions between fully integrated D-SNPs (FIDE SNPs) and highly integrated (HIDE SNPs); (2) permissibility of carve-outs of behavioral health services and long term services and supports (LTSS) for FIDE SNPs and HIDE SNPs; (3) alignment of D-SNP and companion Medicaid plan service areas; and (4) compliance with integration requirements for D-SNPs that only enroll partial-benefit dually eligible individuals.

Medicare and Medicaid Programs; Programs of All-Inclusive Care for the Elderly (PACE)

This Centers for Medicare & Medicaid Services (CMS) final rule strengthens patient protections, improves care coordination, and provides administrative flexibilities and regulatory relief for Programs of All-Inclusive Care for the Elderly (PACE). The final rule removes redundancies and eliminates outdated information, which will reduce administrative burden on PACE organizations, and allow clinicians and other care providers to focus more of their time on patients.