Massachusetts Medical Society: Comments Regarding Medicare-Medicaid Integration Demonstration for Massachusetts

Comments Regarding Medicare-Medicaid Integration Demonstration for Massachusetts

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.

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