NAMD Sends Comments on CMS’ Proposed Policies on Dually-Eligible Members

On March 7, 2022, NAMD submitted comments on CMS’ CY 2023 Medicare Advantage and Part D Proposed Rule (CMS-4192- P), which would impact how states provide care for dually-eligible members. In general, NAMD is supportive of the proposed rule’s aim of promoting care integration for these members and many of the specific provisions in the rule (such as requiring D-SNP advisory committees, integrated materials, unified appeals processes, and changes to the calculation of maximum out-of-pocket limits) . However, some provisions in the proposed rule – including the conversion of Medicare-Medicaid plans (MMPs) to D-SNPs – may lead to increased administrative burden for state Medicaid programs, disruptions in care for members, and other operational challenges.