The MLTSS Association and SNP Alliance sent a letter to Congress with comments on the DUALS Act of 2024, which aims to improve integrated care for dually eligible beneficiaries under a new Title XXII. We praise the inclusion of policies like passive enrollment, SSBCI eligibility expansion, a universal frailty adjuster, and continuous eligibility. However, we urge Congress to apply these policies to the existing D-SNP framework instead of creating a new program, citing potential confusion and administrative challenges. We recommend careful incremental changes, collaboration with CMS, and additional support for states.
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