NAMD Comments on Proposed Policies Impacting Care for Dually Eligible Individuals

On January 26, NAMD formally commented on the Medicare Contract Year 2027 proposed rule, which included several policies that would impact care for individuals who are dually eligible for Medicare and Medicaid. These provisions include policies aimed at changes to the Model of Care (MOC) off-cycle submission timing, revisions to passive enrollment, and policy adjustments to allow continued dual-eligible special needs plan (D-SNP) enrollment for Medicaid fee-for-service (FFS) populations in states and territories with voluntary Medicaid managed care. The rule would also clarify CMS’ authority to immediately terminate a D-SNP contract when its state Medicaid agency contract (SMAC) ends and would formalize limits on D-SNP-only contracts using multi-contract entity (MCE) submissions.

NAMD generally supports these proposed changes and appreciates CMS’ continued focus on strengthening Medicare-Medicaid integration through D-SNPs. Medicaid agencies have made significant investments in recent years to use D-SNPs to reduce fragmented care, improve coordination across Medicare and Medicaid benefits, and promote aligned enrollment for dually eligible individuals. Given persistent variation across states and territories in D-SNP enrollment, the characteristics of the dually eligible population, delivery system design, and provider network capacity, NAMD encourages CMS to preserve flexibility for Medicaid agencies in D-SNP policy. Such flexibility is essential to allow states and territories to tailor D-SNP approaches to reflect local program structures and market conditions while continuing to advance integrated care for dually eligible individuals.

Read NAMD’s full comments here