The CMS requires FIDE plans to be fully aligned by January 1^st, 2025. A FIDE SNP is a special kind of Medicare managed care plan that coordinates all covered Medicare and Medicaid benefits in one health plan. This integration is intended to improve coordination and reduce fragmentation in healthcare services. This means that the Medicaid plan and the Medicare Advantage plan must be the same carrier and must be the dual plan. Under this requirement, members will have reduced choice in their health plans. State variability in structure and administration means that some members will have significantly more choice and freedom.

State specific lock in policies and the disparity between state policies are an area of concern. In Arizona, beneficiaries can only change their Medicaid plan during their specific enrollment month, which is typically tied to their initial enrollment date. This means members have limited flexibility and may face long waits to switch plans if their needs change or if they are not satisfied with their current plan. In California there is minimal restriction on changing Medicaid plans, allowing members to switch at will. This flexibility can help beneficiaries better align their Medicare and Medicaid coverage and adjust their plans based on evolving needs or satisfaction levels.

There is a disparity of choice, which is an issue of concern. The difference in lock-in policies means that beneficiaries in states with restrictive policies (like Arizona) may struggle to align their Medicare Advantage and Medicaid plans to meet their needs or preferences, compared to those in states with more flexible policies (like California). This can lead to unequal access to benefits and services. In states with more restrictive lock-in policies, beneficiaries may find it challenging to optimize their benefits or adjust their plans to get the best possible coverage. This could affect their overall satisfaction and health outcomes.

CMS would like to fully align all dually eligible members by 2026. While CMS may view this as a cost-saving measure and an improvement in care coordination, the policy has several unintended negative consequences, particularly for vulnerable populations such as those with disabilities and low-income individuals. Individuals with developmental and other disabilities often have complex healthcare needs that might not be fully addressed by a single plan. They may rely on specialized services or providers that could be more accessible under separate Medicare and Medicaid plans. Requiring full alignment might limit their ability to choose plans that best meet their unique needs, potentially affecting their quality of care and overall satisfaction. Examples:

1. The networks are not the same.  The Medicaid network of physicians and the Medicare network of physicians are not the same.  In Arizona the network can vary 10-15% between the Medicaid plan and the dual Medicare Advantage plan.

Example 1: The Mayo clinic will not accept a Medicare Advantage plan.  I currently have a client on their transplant list.  If he was forced to take a dual Medicare Advantage plan, he would lose his place in line and lose his physicians.

Example 2: A developmentally disabled member uses Medicaid and an employer plan.  They have doctors that do not accept Medicaid.  When they qualify for Medicare, they select a PPO plan because doctors are more important than the additional benefits of a dual Medicare Advantage plan.

• Members need different benefits depending on their needs. Each dual Medicare Advantage plan offers slightly different benefits.  A member may need a grocery card and select the plan with the highest monthly amount.  Another member may need dental and switch to a company that has the highest dental.  Each member needs different things, and they should have the same choice as other members.

The CMS policy to fully align dually eligible members means they are:

1. Limiting plan options significantly.  This is discriminatory.  Every beneficiary deserves equal access and choice.
2. Reducing flexibility to tailor their needs while allowing other beneficiaries this choice.
3. Losing access to important providers by not allowing choice.
4. Limiting access to select a plan that aligns with their financial or medical needs. Could exacerbate disparities between the dually eligible and those who are not dually eligible.  

As a mother and advocate for those with developmental disabilities, this policy is highly discriminatory.  We have a saying “nothing about us without us.”  CMS has made assumptions of what the dually eligible need and why the dually eligible do not align their plans.  We need voice and choice!