Medicaid Managed Care Beneficiaries to Be Enrolled in Affiliated Medicare Advantage Plans at Age 65

The Department of Health (DOH) announced its intention to institute default enrollment of Medicaid managed care beneficiaries into Medicare Advantage plans at a stakeholder meeting last week. The meeting also covered the transition of Fully Integrated Duals Advantage (FIDA) plan members to affiliated Medicaid Advantage Plus (MAP) plans as the FIDA program winds down, and it explored options for strengthening the Medicare and Medicaid integration of MAP plans. The meeting slides are available here.

Default Enrollment into Medicare Advantage of New Dual Eligibles Enrolled in Mainstream Managed Care

The Department is pursuing default enrollment due to concerns about the lack of care management for the more than 500,000 dually eligible Medicaid beneficiaries who receive coverage through fee-for-service (FFS) Medicare and Medicaid. Approximately 60,000 mainstream Medicaid managed care members turn 65 annually, and most revert to FFS coverage upon attaining Medicare eligibility. Under the Department’s default enrollment plan, beneficiaries would receive a notice of their impending default enrollment and a description of the options available to them, including Programs of All-Inclusive Care for the Elderly (PACE). If they do not select a plan or elect FFS, they would be automatically enrolled in the Dual Eligible Special Needs Plan (D-SNP) and Medicaid Advantage (MA) plan (or MAP plan, if they qualify for long term care) affiliated with their mainstream plan. Beneficiaries would have an opportunity to opt out of the enrollment. Currently, only one mainstream plan has both an affiliated MA and MAP, two additional mainstream plans have an affiliated MAP, and two additional mainstream plans have an affiliated MA.

LeadingAge NY staff raised concerns about the possibility that the long term care needs of frail elderly beneficiaries might be overlooked in the automated enrollment process. Further, we noted that enrollment in plans sponsored by long term care providers might be diverted to plans operated by entities that sponsor mainstream plans but lack experience in serving individuals with long term care needs. LeadingAge NY submitted written comments in response to this proposal earlier in the year.

FIDA Transition

In addition to the default enrollment of mainstream Medicaid managed care beneficiaries into D-SNPs, DOH described plans to passively enroll FIDA members into the MAP plan associated with their FIDA plan upon the expiration of the FIDA program. There are currently six FIDA plans in operation with a total of almost 4,000 members. FIDA members in a given county can be passively enrolled into an affiliated MAP plan if three tests are met in the pertinent county:

Financial test: MAP Medicare costs are no more than the costs associated with Medicare FFS;
Benefits test: MAP benefits are comparable to FIDA; and
Network test: MAP Medicare network is comparable to the FIDA network.

The Department recognizes that the FIDA program includes certain non-traditional, waiver-type benefits that are not currently included in MAP. They are working with the Centers for Medicare and Medicaid Services (CMS) to arrive at a reasonable approach to this test, given low utilization of these benefits.

With the expiration of FIDA looming at the end of 2019, CMS’s findings in relation to the three tests and the timing of the various implementation steps will be critical. By the end of March, the Department anticipates receiving an “early read” from CMS concerning the outcomes of the tests. In addition, plans will be authorized to begin marketing their MAP plans to their FIDA members. In late May, FIDA plans will stop accepting new members with coverage dates after July 1^st. In August, CMS will issue its final county-specific findings on the three tests. Passive enrollment will begin in October, and in December, members who have opted out of passive enrollment and have not selected a different integrated option will revert to Medicare FFS and be auto-assigned to the partially-capitated managed long term care (MLTC) plan associated with their FIDA plan.

Strengthening Medicare and Medicaid Integration in MA and MAP Plans

The Department also discussed options for improving the integration of the Medicare and Medicaid components of MAP and MA plans. Specifically, the Department intends to:

Pursue CMS approval of integrated grievance and appeal processes similar to the FIDA procedures. However, appeals can be integrated at the plan level only for plans that qualify as Fully Integrated Dual Eligible SNPs (FIDE-SNPs) or Highly Integrated Dual Eligible SNPS (HIDE-SNPs). Subject to CMS approval, integration of MAP grievances and appeals would commence in 2020.
Allow integrated marketing materials for the Medicare and Medicaid components of MAP. The Department is seeking feedback from plans concerning the use of uniform marketing templates and joint CMS and DOH review of the integrated marketing materials.
Seek aligned enrollment dates for the Medicare and Medicaid components of MAP and MA. The FIDA procedures for aligning enrollment are not available under MAP. However, the State is exploring the process used by Minnesota, which entails contracting with an independent entity to manage integrated enrollment. Integrated enrollment processes are likely to be implemented in 2021 at the earliest.

Contact: Karen Lipson, klipson@leadingageny.org, 518-867-8383 ext. 124