On January 5th, 2024, the MLTSS Association submitted comments on CMS’ 2025 Medicare Advantage and Part D proposed rule. Among its provisions, the rule proposes several new expansive policies to promote aligned enrollment in dual-eligible special needs plans (D-SNPs), implements new documentation and outreach requirements for supplemental benefits, and institutes new network adequacy requirements for behavioral health providers. Our comments primarily focused on key implications for dually eligible beneficiaries, including how the aligned enrollment provisions may impact enrollee choice, partial-benefit dually eligible enrollees, state Medicaid MLTSS market dynamics, enrollment processes, enrollee transitions, and overall state capacity.
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