Medicare-Medicaid Coordination Office Releases FY 2013 Report to Congress
March 22, 2014 10:36 AM
On March 13, the Medicare-Medicaid Coordination Office of the Centers for Medicare & Medicaid Services (MMCO CMS) released its Fiscal Year 2013 Report to Congress (the Report). The Report discussed key developments from MMCO CMS, as well as its legislative recommendations. The National Council on Medicaid Home Care – a NAHC affiliate - discusses the highlights of this Report, below:
Expand PACE to individuals between ages 21 and 55. As previously stated in the President’s March 4 budget proposal for the Department of Health and Human Services (HHS) for Fiscal Year 2015 (the Budget Proposal), the Report recommended to expand the Program for All-Inclusive Care for the Elderly (PACE) to those aged 21 through 55. PACE is a rebalancing program that provides community based long-term services and supports (LTSS) to dual eligibles via an interdisciplinary team. The Budget Proposal projected that this would have no budgetary impact. For details, see pages 81-82, here.
Analysis.The Council supports continued efforts at rebalancing, as evidenced in the president’s recent budget proposal, including not only the proposal to expand PACE, but to expand Money Follows the Person (MFP) and to provide HCBS to children eligible for psychiatric residential treatment facilities. For a recent Council article on the Budget Proposal, please click here.
Integrate Appeals Process. MMCO CMS, echoing last year’s report, recommended that Congress integrate the appeals process for dual eligibles. Different appeals processes currently exist between Medicaid and Medicare, and among the various parts of Medicare. While the Report comments that the Medicare-Medicaid Financial Alignment Demonstrations (Duals Demos) are working to integrate financing and service delivery of dual eligibles, an integrated appeals process would permit even greater efficiencies for stakeholders. The Report asks Congress to give more authority to the Secretary of the Department of Health and Human Services (HHS) to develop an integrated appeals system.
Areas of Interest
Coverage standards. The Report also stated areas of interest MMCO CMS is pursuing to “improve the experience” of dual eligibles, including coverage standards. MMCO CMS recognizes that Medicare and Medicaid coverage standards can overlap, and often have different rules, as in home health care.
Analysis. While MMCO CMS did not highlight a specific game plan regarding varying and overlapping coverage standards, the Council supports clear Medicare/Medicaid coverage standards for duals. The Council also continues to advocate for minimal federal standards for home health coverage under Medicaid, including calling on Congress to expand the mandatory Medicaid home health benefit to include speech, occupational and physical therapy, and medical social work, as well as hospice care. Congress should also set minimum standards regarding the frequency and duration of care. The Council opposes block grants and other proposals which would grant states full authority to determine the scope, amount, and duration of home care benefits. For details, see the Council’s policy blueprint, page 32, and 61-62, here.
Various funding opportunities
After providing a brief review of the status of the Duals Demos, the Report gave updates on various funding opportunities in place with regard to dual eligibles.
Implementation. States that have signed memoranda of understanding (MOUs) with CMS for the Duals Demos are eligible to receive additional funds for implementation activities such as those that protect beneficiary rights and foster beneficiary participation generally. CMS has awarded such additional funds to California, Massachusetts, Minnesota, New York, and Washington. This funding opportunity has closed, as CMS is no longer receiving applications for it. For details on this funding opportunity, see here.
Ombudsman. CMS will also fund ombudsman programs of the Duals Demos, provided they have met certain requirements. CMS has so far extended awards to California, Illinois, and Virginia. For more information, click here.
SHIPs and ADRCs. CMS has also agreed to provide funds for State Health Insurance Counseling and Assistance Programs (SHIPs) and Aging and Disability Resource Centers (ADRCs) to enable these institutions to counsel dual eligibles. CMS provided awards to Washington State in 2012, and California, Illinois, Virginia, and Massachusetts in 2013. For more information, click here.
Analysis. The Council supports these additional funding opportunities generally. It remains skeptical of the overall strength of the ombudsman program. While addressing funding concerns, CMS had a very measured response to lingering stakeholder concerns regarding staffing and appropriate training of the ombudsmen prior to Demonstration enrollment. The Council analyzed that the duals MOUs largely fell short of the “five key elements” that an ombudsman program shouldhave to secure beneficiary rights, as identified by stakeholders. For previous Council briefs on the Duals ombudsman programs, including the “five key elements” and CMS’s measured response to an advocacy letter signed by the Council, click here and here.
The Report also addressed the need to improve quality of care for the dual eligibles. It is doing this in partnership with the National Quality Forum, and together they have begun to develop quality measures for long term services and supports (LTSS). For a recent Council brief on this, click here.
Lastly, the Report commented on the need to improve data gathering on the dual population to further better care, and MMCO CMS’ progress in that regard. For details, see pages 16-18 of the Report, here.
The Council continues to make dual eligibles a priority in its advocacy efforts. For its 2014 policy priorities, in addition to those stated above, the Council has placed emphasis on: establishing reasonable standards for consolidation of Medicare fee-for service payments with Medicaid for dual-eligible beneficiaries; restricting passive enrollment of dual eligibles in Medicare Advantage plans; and promoting Medicare-Medicaid coordination, especially with regard to streamlining payment recovery of providers for care to dual eligibles. For details, see pages 59-62 of the Council’s policy blueprint, here.
Home care providers are encouraged to keep abreast of developments regarding dual eligibles on CMS’ website, and to contact the Council with any questions or concerns.