The Massachusetts Medical Society appreciates the
opportunity to provide comment to the Medicare-Medicaid Integration
Demonstration for Massachusetts (Duals Demonstration 2.0.) The Medical Society
commends the MassHealth administration for their engagement with the physician
community, and with the broader stakeholder community throughout the
development of this proposal.
The Medical Society strongly supports the One Care and
Senior Care Options (SCO) programs as important programs through which to
provide integrated, coordinated care for a population that is often associated
with complex medical needs. The Medical Society has been impressed with
preliminary data indicating strong performance in these programs in both
patient experience and quality measures. And because of the financial strain
that dual eligible populations place on MassHealth budgets, especially in the
fee-for-service settings, MMS also supports the thoughtful growth of enrollment
in One Care and SCO.
The Medical Society urges the MassHealth administration to
look closely at experiences from the ACO/MCO transition process from Spring of
2018: lessons learned can undoubtedly be applied to this current dual eligible
reform process in areas such as passive enrollment, member communications, and
flexibility in active enrollment. MMS believes that properly addressing lessons
learned from the early weeks of the ACO/MCO rollout could substantially improve
any approved reform to these dual eligible programs.
Specifically, the Medical Society offers the following
comments:
MMS supports the
proposed reforms related to member communications and member appeals.
MMS supports the proposal to streamline the currently
two-sourced communications to patients into a single stream communications
platform. Dual eligible programs are already complex from a patient
perspective; this complexity should not be needlessly exacerbated by receiving
concurrent and at times not entirely consistent messaging. Physicians observed
first-hand the critical importance of good communications during the ACO/MCO
reform process. Simple instances of misunderstanding or ambiguity could lead
patients down paths toward far greater confusion, and at worst, finding
themselves in plans that are not in their best interest. In addition, MMS has
long supported robust appeals and grievances processes. Further streamlining of
these processes is strongly supported by MMS.
MMS supports
expansion of One Care and SCO, but urges strong attention to the enrollment
process to maintain existing patient-physician relationships.
MMS has long underscored the importance of prioritizing
continuity of patient-physician relationships in passive enrollment policies.
We believe this sentiment was made evident during the ACO-MCO process, as many
patients emphasized the importance of ensuring continuity of these
relationships during their ACO selection. MMS supports passive enrollment of
“new duals.” For rest of the duals population, MMS commends MassHealth for
their commitment to continuing the “intelligent assignment” approach, which
matches members to plans based upon claims history and existing provider
relationships, but MMS strongly urges flexibility in this process. As we
observed in the ACO-MCO experience, even the most intelligent assignment
systems cannot account for certain unique considerations of individual
patients. MMS therefore urges MassHealth to approach this assignment with flexibility,
and design appeals processes and customer support to address individual cases
of concern.
MMS opposes proposed
reimbursement caps for physicians caring for One Care and SCO members.
MMS appreciates the net impact on many physicians’ overall reimbursement
via the movement of patients from dual eligible fee for service to One Care and
SCO programs. However, we oppose the introduction of the proposed guardrails,
which insert hard reimbursement caps into arrangements negotiated between
private One Care and SCO plans and provider organizations. MMS is concerned
that the introduction of these hard caps on reimbursement could reduce
reimbursement across multiple plans and/or products, and could establish
precedent upon which plans that negotiate unfavorable contracts can request
intervention by public payers. Instead, we urge that the administration work
with health plans and providers to encourage private contracts that are
sustainable for all parties.
In summary, the Medical Society continues to provide strong
support for coordinated, integrated care for dual eligible beneficiaries. MMS
therefore supports many of the reforms contained in the Duals Demonstration 2.0,
including streamlined communications and member appeals. In other areas, such
as the passive enrollment process, MMS urges close attention to members needs
and concerns as it proceeds. And in other areas of this proposal, such as the
reimbursement guardrail, MMS urges consideration of alternative strategies to
ensure sustainability of all parties involved.
