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CMS Approves Launch of Demonstration to Manage Care for All Dual Eligibles -
29 Aug, 2013
On August 26, 2013, CMS approved a "Memorandum of Understanding" (MOU) between NYS and DOH to launch a demonstration program by which "dual eligibles" - people who have both Medicare and Medicaid - will enroll in managed care plans that cover not only Medicaid long-term care services, as MLTC plans do, but also cover ALL other medical care covered by Medicare and Medicaid. In other words, a FIDA member will essentially trade in ALL of their insurance cards -- Medicare, Medicaid, MLTC, Medigap, and Medicare Part D -- and only have one health plan -- their FIDA plan.
As a demonstration program, NYS is targeting a smaller group of dual eligibles, not the whole state. Not coincidentally, the target group are the SAME PEOPLE who were required to enroll in MLTC plans - those adults age 21+ who need community-based long term care services, who have Medicare and Medicaid, and who live in certain areas - NYC, Long Island, and Westchester. People in the OPWDD and TBI waivers will be exempt, but people in the Nursing Home Transition & DIversion Waiver will be in the demonstration. People living in nursing homes will also be in the demonstration, but on a different timeline.
Passive Enrollment and Opting Out-- Unlike MLTC, enrollment in a FIDA plan is not "mandatory." MLTC members may choose to stay in an MLTC plan and use their Original Medicare or Medicare Advantage cards for their primary medical care. However, FIDA will use a "passive enrollment" with the right to "opt-out." In July 2014, MLTC members will receive notice that they may "voluntarily" enroll in a FIDA plan (and will be heavily marketed by their MLTC plans to join the one sponsored by the same company that sponsors the MLTC plan). If they don't join a plan "voluntarily," and do not affirmatively OPT OUT prior to Oct. 1, 2014, they will be "passively enrolled" into a plan effective Oct. 1, 2014. They will have the right to disenroll after that date at any time, but since enrollment is by the month, there may be a delay in which they will not have access to their preferred doctors and other providers, if they are not in the FIDA plan's network. People in nursing homes will have the same passive enrollment process, but a few months behind those in MLTC plans.
More information will be posted on this website. For now, see these resources:
Earlier History of FIDA --
The State DOH filed its final proposal for a Fully Integrated Dual Eligible (FIDA) managed care plan with the federal government on May 25, 2012.
The State filed this final proposal on May 25th, one week after receiving comments by consumer advocates and other stakeholders on its previous draft on May 17, 2012. These consumer advocate comments filed by Medicare Rights Center, the Center for Disability Rights, Center for Independence of the Disabled NY, Community Services Society of NY, Empire Justice Center, Legal Aid Society, New York Association on Independent Living, and are posted here. The comments raise many concerns about the "passive enrollment" model, in which individuals will be automatically assigned to a plan with the right to opt-out. Other concerns are voiced about adequacy of the plan's networks of providers -- will people with chronic health conditions have access to specialists they need? Also discussed are oversight and accountability, grievance and hearing rights, contracting requirements and payment models to incentivize adequate care, and compliance with the Americans with Disabilities Act.