mr RICHARD BRINGEWATT

Advocated for changes in methods used to measure SNP performance under STARS to more effectively account for influences of social, education, and economic factors that affect health and health outcomes for persons dually eligible for Medicare and Medicaid. Current provisions do not fully account for factors that influence health and health related outcomes; Advocated for provisions to improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities (including people who are homeless) and other persons with complex medical conditions such as HIV AIDS ESRD and SPMI. These are the most costly and complex care subgroups of the dually eligible population; Worked with the Medicare-Medicaid Coordination Office, Congress, and others toward better aligning Medicare and Medicaid policies and procedures for persons dually eligibly for Medicare and Medicaid; Provided strategic advice and support to the SNP Alliance regarding their advancing an advocacy agenda for high-risk/high-need persons;

Advocated for changes in methods used to measure SNP performance under STARS to more effectively account for influences of social, education, and economic factors that affect health and health outcomes for persons dually eligible for Medicare and Medicaid. Current provisions do not fully account for factors that influence health and health related outcomes; Advocated for provisions to improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities (including people who are homeless) and other persons with complex medical conditions such as HIV AIDS ESRD and SPMI. These are the most costly and complex care subgroups of the dually eligible population; Worked with the Medicare-Medicaid Coordination Office, Congress, and others toward better aligning Medicare and Medicaid policies and procedures for persons dually eligibly for Medicare and Medicaid; Provided strategic advice and support to the SNP Alliance regarding their advancing an advocacy agenda for high-risk/high-need persons;

Advocated for changes in methods used to measure SNP performance under STARS to more effectively account for influences of social, education, and economic factors that affect health and health outcomes for persons dually eligible for Medicare and Medicaid. Current provisions do not fully account for factors that influence health and health related outcomes; Advocated for provisions to improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities (including people who are homeless) and other persons with complex medical conditions such as HIV AIDS ESRD and SPMI. These are the most costly and complex care subgroups of the dually eligible population; Worked with the Medicare-Medicaid Coordination Office, Congress, and others toward better aligning Medicare and Medicaid policies and procedures for persons dually eligibly for Medicare and Medicaid; Provided strategic advice and support to the SNP Alliance regarding their advancing an advocacy agenda for high-risk/high-need persons;

Advocated for changes in methods used to measure SNP performance under STARS to more effectively account for influences of social, education, and economic factors that affect health and health outcomes for persons dually eligible for Medicare and Medicaid. Current provisions do not fully account for factors that influence health and health related outcomes; Advocated for provisions to improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities (including people who are homeless) and other persons with complex medical conditions such as HIV AIDS ESRD and SPMI. These are the most costly and complex care subgroups of the dually eligible population; Worked with the Medicare-Medicaid Coordination Office, Congress, and others toward better aligning Medicare and Medicaid policies and procedures for persons dually eligibly for Medicare and Medicaid; Provided strategic advice and support to the SNP Alliance regarding their advancing an advocacy agenda for high-risk/high-need persons;

Continued to promote permanent extension of legislative authority for all types of Special Needs Plans in conjunction with related SNP-related provisions. Permanency and related provisions are important to provide stability for plans and states involved in advancing specialized managed care programs and for special needs individuals. This will also improve the viability of SNPs in fulfilling their Congressional established specialty care mandate. Advocated for changes in methods used to measure SNP performance under STARS to more effectively account for influences of social, education, and economic factors that affect health and health outcomes for persons dually eligible for Medicare and Medicaid beyond what exists for persons of higher income, education, and social and economic status. Current provisions do not fully account for factors that influence health and health related outcomes. Advocated for Congress to expedite the alignment of Medicare and Medicaid financing policy and oversight for persons dually eligible for Medicare and Medicaid, including efforts to strengthen the role of the Dual Office to serve as a possible arbitrator in resolving key differences between Medicare and Medicaid. Advocated for provisions to improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities, and other persons with complex medical conditions, such as HIV/AIDS, ESRD, and SMPM: These are the most costly and complex care subgroups of the dually eligible population. Worked with the Medicare/Medicaid Coordination Office, Congress, and others toward better aligning Medicare and Medicaid policies and procedures for persons dually eligibly for Medicare and Medicaid. Advocated for specific improvements in policy and oversight for Institutional SNPs and Chronic Conditions SNPs to better enable them to address the unique needs of complex care beneficiaries. Provided strategic advice and support to the SNP Alliance regarding their advancing an advocacy agenda for high-risk/high-need persons.

Continued to promote permanent extension of legislative authority for all types of Special Needs Plans in conjunction with related SNP-related provisions. Permanency and related provisions are important to provide stability for plans and states involved in advancing specialized managed care programs and for special needs individuals. This will also improve the viability of SNPs in fulfilling their Congressional established specialty care mandate. Advocated for changes in methods used to measure SNP performance under STARS to more effectively account for influences of social, education, and economic factors that affect health and health outcomes for persons dually eligible for Medicare and Medicaid beyond what exists for persons of higher income, education, and social and economic status. Current provisions do not fully account for factors that influence health and health related outcomes. Advocated for Congress to expedite the alignment of Medicare and Medicaid financing policy and oversight for persons dually eligible for Medicare and Medicaid, including efforts to strengthen the role of the Dual Office to serve as a possible arbitrator in resolving key differences between Medicare and Medicaid. Advocated for provisions to improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities, and other persons with complex medical conditions, such as HIV/AIDS, ESRD, and SMPM: These are the most costly and complex care subgroups of the dually eligible population. Worked with the Medicare/Medicaid Coordination Office, Congress, and others toward better aligning Medicare and Medicaid policies and procedures for persons dually eligibly for Medicare and Medicaid. Advocated for specific improvements in policy and oversight for Institutional SNPs and Chronic Conditions SNPs to better enable them to address the unique needs of complex care beneficiaries. Provided strategic advice and support to the SNP Alliance regarding their advancing an advocacy agenda for high-risk/high-need persons.

Continued to promote permanent extension of legislative authority for all types of Special Needs Plans in conjunction with related SNP-related provisions. Permanency and related provisions are important to provide stability for plans and states involved in advancing specialized managed care programs and for special needs individuals. This will also improve the viability of SNPs in fulfilling their Congressional established specialty care mandate. Advocated for changes in methods used to measure SNP performance under STARS to more effectively account for influences of social, education, and economic factors that affect health and health outcomes for persons dually eligible for Medicare and Medicaid beyond what exists for persons of higher income, education, and social and economic status. Current provisions do not fully account for factors that influence health and health related outcomes. Advocated for Congress to expedite the alignment of Medicare and Medicaid financing policy and oversight for persons dually eligible for Medicare and Medicaid, including efforts to strengthen the role of the Dual Office to serve as a possible arbitrator in resolving key differences between Medicare and Medicaid. Advocated for provisions to improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities, and other persons with complex medical conditions, such as HIV/AIDS, ESRD, and SMPM: These are the most costly and complex care subgroups of the dually eligible population. Worked with the Medicare/Medicaid Coordination Office, Congress, and others toward better aligning Medicare and Medicaid policies and procedures for persons dually eligibly for Medicare and Medicaid. Advocated for specific improvements in policy and oversight for Institutional SNPs and Chronic Conditions SNPs to better enable them to address the unique needs of complex care beneficiaries. Provided strategic advice and support to the SNP Alliance regarding their advancing an advocacy agenda for high-risk/high-need persons.

Continued to promote permanent extension of legislative authority for all types of Special Needs Plans in conjunction with related SNP-related provisions. Permanency and related provisions are important to provide stability for plans and states involved in advancing specialized managed care programs and for special needs individuals. This will also improve the viability of SNPs in fulfilling their Congressional established specialty care mandate. Advocated for changes in methods used to measure SNP performance under STARS to more effectively account for influences of social, education, and economic factors that affect health and health outcomes for persons dually eligible for Medicare and Medicaid beyond what exists for persons of higher income, education, and social and economic status. Current provisions do not fully account for factors that influence health and health related outcomes. Advocated for Congress to expedite the alignment of Medicare and Medicaid financing policy and oversight for persons dually eligible for Medicare and Medicaid, including efforts to strengthen the role of the Dual Office to serve as a possible arbitrator in resolving key differences between Medicare and Medicaid. Advocated for provisions to improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities, and other persons with complex medical conditions, such as HIV/AIDS, ESRD, and SMPM: These are the most costly and complex care subgroups of the dually eligible population. Worked with the Medicare/Medicaid Coordination Office, Congress, and others toward better aligning Medicare and Medicaid policies and procedures for persons dually eligibly for Medicare and Medicaid. Advocated for specific improvements in policy and oversight for Institutional SNPs and Chronic Conditions SNPs to better enable them to address the unique needs of complex care beneficiaries. Organized and facilitated business round table of executive members of the SNP Alliance with various panels of national experts and representatives from the Center for Medicare and Medicare.

Continued to promote permanent extension of legislative authority for all types of Special Needs Plans in conjunction with related SNP-related provisions. Permanency and related provisions are important to provide stability for plans and states involved in advancing specialized managed care programs and for special needs individuals. This will also improve the viability of SNPs in fulfilling their Congressional established specialty care mandate. Advocated for changes in methods used to measure SNP performance under STARS to more effectively account for influences of social, education, and economic factors that affect health and health outcomes for persons dually eligible for Medicare and Medicaid beyond what exists for persons of higher income, education, and social and economic status. Current provisions do not fully account for factors that influence health and health related outcomes. Advocated for Congress to expedite the alignment of Medicare and Medicaid financing policy and oversight for persons dually eligible for Medicare and Medicaid, including efforts to strengthen the role of the Dual Office to serve as a possible arbitrator in resolving key differences between Medicare and Medicaid. Advocated for provisions to improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities, and other persons with complex medical conditions, such as HIV/AIDS, ESRD, and SMPM: These are the most costly and complex care subgroups of the dually eligible population. Worked with the Medicare/Medicaid Coordination Office, Congress, and others toward better aligning Medicare and Medicaid policies and procedures for persons dually eligibly for Medicare and Medicaid. Advocated for specific improvements in policy and oversight for Institutional SNPs and Chronic Conditions SNPs to better enable them to address the unique needs of complex care beneficiaries. Organized and facilitated business round table of executive members of the SNP Alliance with various panels of national experts and representatives from the Center for Medicare and Medicare.

Continued to promote permanent extension of legislative authority for all types of Special Needs Plans in conjunction with related SNP-related provisions. Permanency and related provisions are important to provide stability for plans and states involved in advancing specialized managed care programs and for special needs individuals. This will also improve the viability of SNPs in fulfilling their Congressional established specialty care mandate. Advocated for changes in methods used to measure SNP performance under STARS to more effectively account for influences of social, education, and economic factors that affect health and health outcomes for persons dually-eligible for Medicare and Medicaid beyond what exists for persons of higher income, education, and social and economic status. Current provisions do not fully account for factors that influence health and health-related outcomes. Advocated for Congress to expedite the alignment of Medicare and Medicaid financing policy and oversight for persons dually-eligible for Medicare and Medicaid, including efforts to strengthen the role of the Dual Office to serve as a possible arbitrator in resolving key differences between Medicare and Medicaid. Advocated for provisions to improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities, and other persons with complex medical conditions, such as HIV/AIDS, ESRD, and SMPM: These are the most costly and complex care subgroups of the dually-eligible population. Worked with the Medicare/Medicaid Coordination Office, Congress, and others toward better aligning Medicare and Medicaid policies and procedures for persons dually-eligible for Medicare and Medicaid. Advocated for CMS to make additional improvements in the predictive accuracy of MA-HCC for high-risk/high-need beneficiaries. Conferred with the Government Accountability Office (GAO) about the study the Office is conducting on the CMS efforts to validate Medicare Advantage (MA) encounter data and its plans and time frames for using the data. Advocated for specific improvements in policy and oversight for Institutional SNPs and Chronic Conditions SNPs to better enable them to address the unique needs of complex care beneficiaries.

Continued to promote permanent extension of legislative authority for all types of Special Needs Plans in conjunction with related SNP-related provisions. Permanency and related provisions are important to provide stability for plans and states involved in advancing specialized managed care programs and for special needs individuals. This will also improve the viability of SNPs in fulfilling their Congressional established specialty care mandate. Advocated for changes in methods used to measure SNP performance under STARS to more effectively account for influences of social, education, and economic factors that affect health and health outcomes for persons dually-eligible for Medicare and Medicaid beyond what exists for persons of higher income, education, and social and economic status. Current provisions do not fully account for factors that influence health and health-related outcomes. Advocated for Congress to expedite the alignment of Medicare and Medicaid financing policy and oversight for persons dually-eligible for Medicare and Medicaid, including efforts to strengthen the role of the Dual Office to serve as a possible arbitrator in resolving key differences between Medicare and Medicaid. Advocated for provisions to improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities, and other persons with complex medical conditions, such as HIV/AIDS, ESRD, and SMPM: These are the most costly and complex care subgroups of the dually-eligible population. Worked with the Medicare/Medicaid Coordination Office, Congress, and others toward better aligning Medicare and Medicaid policies and procedures for persons dually-eligible for Medicare and Medicaid. Advocated for CMS to make additional improvements in the predictive accuracy of MA-HCC for high-risk/high-need beneficiaries. Conferred with the Government Accountability Office (GAO) about the study the Office is conducting on the CMS efforts to validate Medicare Advantage (MA) encounter data and its plans and time frames for using the data. Advocated for specific improvements in policy and oversight for Institutional SNPs and Chronic Conditions SNPs to better enable them to address the unique needs of complex care beneficiaries.

Advocated for improving the predictive accuracy of MA payment rates for persons dually-eligible for Medicare and Medicaid. In particular, we advocated in support of the Administrations proposal to modify the CMS-HCC payment method to better account for the cost of caring for dual beneficiaries vs non-duals, and for full benefit duals in particular, which represent the poorest of the poor Medicare beneficiaries. Promoted permanent extension of legislative authority for all types of Special Needs Plans, in conjunction with related SNP-related provisions. Permanency and related provisions are important to provide stability for plans and states involved in advancing specialized managed care programs and for special needs individuals. This will also improve the viability of SNPs in fulfilling their Congressional established specialty care mandate. Advocated for changes in methods used to measure SNP performance under STARS to more effectively account for influences of social, education, and economic factors that affect health and health outcomes for persons dually-eligible for Medicare and Medicaid beyond what exists for persons of higher income, education, and social and economic status. Current provisions do not fully account for factors that influence health and health related outcomes. Advocated for Congress to create a legislative/regulatory pathway to better align Medicare and Medicaid for persons dually-eligible for Medicare and Medicaid. Provisions will improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities, and other persons with complex medical conditions, such as HIV/AIDS, ESRD, and SMPM. These are the most costly and complex care subgroups of the dually-eligible population. Worked with the Medicare/Medicaid Coordination Office, Congress, and others toward better aligning Medicare and Medicaid policies and procedures for persons dually-eligible for Medicare and Medicaid.

Advocated for improving the predictive accuracy of MA payment rates for persons dually-eligible for Medicare and Medicaid. In particular, we advocated in support of the Administrations proposal to modify the CMS-HCC payment method to better account for the cost of caring for dual beneficiaries vs non-duals, and for full benefit duals in particular, which represent the poorest of the poor Medicare beneficiaries. Promoted permanent or long-term extension of SNP legislative authority in conjunction with related SNP-related provisions. Permanency and related provisions are important to provide stability for plans and states involved in advancing specialized managed care programs and for special needs individuals. This will also improve the viability of SNPs in fulfilling their Congressional established specialty care mandate. Advocated for changes in methods used to measure SNP performance under STARS to more effectively account for influences of social, education, and economic factors that affect health and health outcomes for persons dually-eligible for Medicare and Medicaid beyond what exists for persons of higher income, education, and social and economic status. Current provisions do not take these factors into account and penalize plans that seek to specialize in care of poor, frail, disabled, chronically ill persons. Advocated for Congress to create a legislative/regulatory pathway to better align Medicare and Medicaid for persons dually-eligible for Medicare and Medicaid. Provisions will improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities, and other persons with complex medical conditions, such as HIV/AIDS, ESRD, and SMPM. These are the most costly and complex care subgroups of the dually-eligible population. Worked with the Medicare/Medicaid Coordination Office, Congress, and others towards advancing the integration of Medicare and Medicaid benefits and services for persons dually-eligible for Medicare and Medicaid. Advocated for various proposals and changes to other proposals outlined by CMS in in their Advance Notice and Draft Call Letter for MA plans to be operating in 2017. Advocated for improving policy for persons with chronic illness, given options being considered by the Senate Finance Committee in conjunction with the SFCs Chronic Care Working Group.

Promoted permanent or long-term extension of SNP legislative authority in conjunction with related SNP related provisions. Permanency and related provisions are important to provide stability for plans and states involved in advancing specialized managed care programs and for special needs individuals; and to improve the viability of SNPs in fulfilling their Congressional established specialty care mandate. Advocated for more fair and appropriate payment methods for SNPs serving high-risk populations, with particular regard for reducing disparities in payment between dually eligible beneficiaries served by Medicare Advantage plans and dually eligible beneficiaries served by providers under Medicare FFS. Advocated for changes in methods used to measure SNP performance under Stars to more effectively address factors, often referred to as social determinants of health, that influence health and health outcomes for dually eligible beneficiaries beyond what exists for persons of higher income, education, and social economic status. Current provisions do not take these factors into account and penalize plans that seek to specialize in care of poor, frail, disabled, chronically ill persons. Advocated for Congress to create a legislative pathway to better align Medicare and Medicaid for persons dually eligible for Medicare and Medicaid. Provisions will improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities, and other persons with complex medical conditions, such as HIVAIDS, ESRD, and SMPM. These are the most costly and complex care sub-groups of the dually eligible population. Worked with the Medicare/Medicaid Coordination Office, Congress, and others towards advancing the integration of Medicare and Medicaid benefits and services for Medicare-Medicaid enrollees. Advocated for improving policy for persons with chronic illness, given options being considered by the Senate Finance Committee in conjunction with the SFCs Chronic Care Working Group. Held annual meeting of SNP Alliance members and other SNP and MMP executives where several Congressional and CMS staff participated on selected discussion panels.

Promoted permanent or long-term extension of SNP legislative authority in conjunction with related SNP related provisions. Permanency and related provisions are important to provide stability for plans and states involved in advancing specialized managed care programs and for special needs individuals; and to improve the viability of SNPs in fulfilling their Congressional-established specialty care mandate. Advocated for changes in methods used to measure SNP performance under Stars to more effectively address factors, often referred to as social determinants of health, that influence health and health outcomes for dually-eligible beneficiaries beyond what exists for persons of higher income, education, and social economic status. Current provisions do not take these factors into account and penalize plans that seek to specialize in care of poor, frail, disabled, chronically ill persons. Advocated that CMS delay termination of MA-SNPs on the basis of low performing icons until such time CMS meaningfully addresses the adverse effects of current Star rating and bonus payment structures on MA-SNP performance ratings. Advocated for Congress to create a legislative pathway to better align Medicare and Medicaid for persons dually-eligible for Medicare and Medicaid. Provisions will improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities, and other persons with complex medical conditions, such as HIVAIDS, ESRD, and SMPM. These are the most costly and complex care subgroups of the dually-eligible population. Advocated for more fair and appropriate payment methods for SNPs serving high-risk populations, with particular regard for reducing disparities in payment between dually-eligible beneficiaries served by Medicare Advantage plans and dually-eligible beneficiaries served by providers under Medicare FFS. Worked with the Medicare/Medicaid Coordination Office, Congress, and others towards advancing the integration of Medicare and Medicaid benefits and services for Medicare-Medicaid enrollees. Advocated for changes in the 2016 Advanced Notice and Call Letter to better enable MA-SNPs to more efficiently and effectively serve high-risk/high-need persons.

Promoted permanent or long-term extension of SNP legislative authority in conjunction with related SNP related provisions. Permanency and related provisions are important to provide stability for plans and states involved in advancing specialized managed care programs and for special needs individuals; and to improve the viability of SNPs in fulfilling their Congressional-established specialty care mandate. Advocated for changes in methods used to measure SNP performance under Stars to more effectively address factors, often referred to as social determinants of health, that influence health and health outcomes for dually-eligible beneficiaries beyond what exists for persons of higher income, education, and social economic status. Current provisions do not take these factors into account and penalize plans that seek to specialize in care of poor, frail, disabled, chronically ill persons. Advocated that CMS delay termination of MA-SNPs on the basis of low performing icons until such time CMS meaningfully addresses the adverse effects of current Star rating and bonus payment structures on MA-SNP performance ratings. Advocated for Congress to create a legislative pathway to better align Medicare and Medicaid for persons dually-eligible for Medicare and Medicaid. Provisions will improve efficiency in program administration and improve methods for serving frail elders, adults with disabilities, and other persons with complex medical conditions, such as HIVAIDS, ESRD, and SMPM. These are the most costly and complex care subgroups of the dually-eligible population. Advocated for more fair and appropriate payment methods for SNPs serving high-risk populations, with particular regard for reducing disparities in payment between dually-eligible beneficiaries served by Medicare Advantage plans and dually-eligible beneficiaries served by providers under Medicare FFS. Worked with the Medicare/Medicaid Coordination Office, Congress, and others towards advancing the integration of Medicare and Medicaid benefits and services for Medicare-Medicaid enrollees. Advocated for changes in the 2016 Advanced Notice and Call Letter to better enable MA-SNPs to more efficiently and effectively serve high-risk/high-need persons.

Promoted Permanent Or Long-Term Extension Of SNP Legislative Authority in conjunction with related SNP-related provisions contained in H.R. 2. Advocated for creating a legislative pathway for the integration of Medicare and Medicaid for persons dually eligible for Medicare and Medicaid. Provisions are important for enabling Special Needs Plans and Medicaire-Medicaid Plans to improve efficiencies in program administration and to establish improved benefits and care methods for serving frail elders, adults with disabilities, and other persons with complex medical conditions, such as HIV-AIDS, ESRD, and SMPM. These are the most costly and complex care subgroups of the dually eligible population. Advocated for changes in methods used to measure SNP performance under Stars to more effectively address factors, often referred to as social determinants of health, that influence health and health outcomes for dually eligible beneficiaries beyond what exists for persons of higher income, education, and social economic status. Current provisions do not take these factors into account and penalize plans that seek to specialize in care of poor, frail, disabled, chronically ill persons. Advocated For Appropriate Medicare Risk Adjusted Payment Methods For SNPs Serving High Risk Populations, Including Reducing The Disparities Between Medicare Advantage Payments For Beneficiaries Who Are Dually Eligible For Medicare And Medicaid, And Medicaid and For Non-Duals, Evaluating And Advocating For Adjustments To Account For Unfunded Costs Associated With Social Determinants Of Health, Ensuring That SNPs Are Not Paid Less Than Fee-For-Service For Beneficiaries Eligible For Medicare And Medicaid Services, And Other Matters; Worked Toward Advancing More Appropriate Basis For The Evaluation And Approval Of Special Needs Plans, Including Aligning Model Of Care Requirements And Structure And Process Measures; Modifying The Star Rating Measures To Be More Relevant To Populations Served By Special Needs Plans; And Risk Adjusting Or Stratifying Measures To Account For The Impact Of Socioeconomic Status On Ratings For Plans Serving Disadvantaged Populations Like Dual Eligible Enrollees; Conducted Executive Roundtable on March 30-31 regarding an array of Special Needs Plan and Medicare-Medicaid Plan issues. Selected Congressional staff and staff from CMS participated in selected sessions as presenters or members of a discussant panel. Worked With The Medicare/Medicaid Coordination Office, Congress, And Others Towards Advancing The Integration Of Medicare And Medicaid Benefits For Medicare-Medicaid Enrollees; Advocated Against The Termination Of Medicare Advantage Special Needs Plans On The Basis Of Low Performing Icons; Requested That CMS Delay The Decision To Act On Termination And To Modify The Time frame During Which Plans Would Be Evaluated For Performance In Relation To Termination; And Worked Wit Congress Is Support Of This Objective. Advocated For An Evaluation Of The Reliability Of Data From Self-Report Survey Instruments When Completed By Persons With Cognitive Impairment Or Mental Illness When Data Are Used For Public Reporting As Part Of The Public Comments On Updates To The Health Outcome Survey.

See Next Page for Narrative.Promoted Permanent Or Long-Term Extension Of SNP Legislative Authority; Advocated For Appropriate Medicare Risk Adjusted Payment Methods For SNPs Serving High Risk Populations, Including Reducing The Disparities Between Medicare Advantage Payments For Beneficiaries Who Are Dually Eligible For Medicare And Medicaid, And Medicaid and For Non-Duals, Evaluating And Advocating For Adjustments To Account For Unfunded Costs Associated With Social Determinants Of Health, Ensuring That SNPs Are Not Paid Less Than Fee-For-Service For Beneficiaries Eligible For Medicare And Medicaid Services, And Other Matters; Worked Toward Advancing More Appropriate Basis For The Evaluation And Approval Of Special Needs Plans, Including Aligning Model Of Care Requirements And Structure And Process Measures; Modifying The Star Rating Measures To Be More Relevant To Populations Served By Special Needs Plans And Risk Adjusting Or Stratifying Measures To Account For The Impact Of Socioeconomic Status On Ratings For Plans Serving Disadvantaged Populations Like Dual Eligible Enrollees; Issues Related To Accounting for Social Determinants Of Health in crafting Payment Methods and Performance Evaluation Metrics. Advocated For Enactment Of HR 4994, The IMPACT Act (''Improving Medicare Post-Acute Care Transformation Act Of 2014'') Which Included Provisions Requiring The Secretary To Carry Out Studies Related To The Impact Of Social Determinants Of Health On Resource Utilization Outcomes And To Account For Such Impacts In The Medicare Payment System; Worked With The Medicare/Medicaid Coordination Office, Congress, And Others Towards Advancing The Integration Of Medicare And Medicaid Benefits For Medicare-Medicaid Enrollees; Advocated Against The Termination Of Medicare Advantage Special Needs Plans On The Basis Of Low Performing Icons; Requested That CMS Delay The Decision To Act On Termination And To Modify The Timeframe During Which Plans Would Be Evaluated For Performance In Relation To Termination; And Worked With Congress Is Support Of This Objective. Advocated For An Evaluation Of The Reliability Of Data From Self-Report Survey Instruments When Completed By Persons With Cognitive Impairment Or Mental Illness When Data Are Used For Public Reporting As Part Of The Public Comments On Updates To The Health Outcome Survey.

See Next Page for Narrative.Promoted Permanent Or Long-Term Extension Of SNP Legislative Authority; Advocated For Appropriate Medicare Risk Adjusted Payment Methods For Snps Serving High Risk Populations, Including Reducing The Disparities Between Medicare Advantage Payments For Beneficiaries Who Are Dually Eligible For Medicare And Medicaid, And Medicaid and For Non-Duals, Evaluating And Advocating For Adjustments To Account For Unfunded Costs Associated With Social Determinants Of Health, Ensuring That Snps Are Not Paid Less Than Fee-For-Service For Beneficiaries Eligible For Medicare And Medicaid Services, And Other Matters; Worked Toward Advancing More Appropriate Basis For The Evaluation And Approval Of Special Needs Plans, Including Aligning Model Of Care Requirements And Structure And Process Measures; Modifying The Star Rating Measures To Be More Relevant To Populations Served By Special Needs Plans; And Risk Adjusting Or Stratifying Measures To Account For The Impact Of Socioeconomic Status On Ratings For Plans Serving Disadvantaged Populations Like Dual Eligible Enrollees; Promoted Amendment And Reintroduction Of Sections 101, 102 And 208 Of S. 2110 And Related Sections Of S. 2553 To Achieve Performance Evaluation Objectives Related To Social Determinants Of Health; Advocated For Enactment Of HR 4994, The IMPACT Act (Improving Medicare Post-Acute Care Transformation Act Of 2014) Which Included Provisions Requiring The Secretary To Carry Out Studies Related To The Impact Of Social Determinants Of Health On Resource Utilization Outcomes And To Account For Such Impacts In The Medicare Payment System; Worked With The Medicare/Medicaid Coordination Office, Congress, And Others Towards Advancing The Integration Of Medicare And Medicaid Benefits For Medicare-Medicaid Enrollees; Advocated Against The Termination Of Medicare Advantage Special Needs Plans On The Basis Of Low Performing Icons; Requested That CMS Delay The Decision To Act On Termination And To Modify The Timeframe During Which Plans Would Be Evaluated For Performance In Relation To Termination; And Worked With Congress Is Support Of This Objective. Advocated For An Evaluation Of The Reliability Of Data From Self-Report Survey Instruments When Completed By Persons With Cognitive Impairment Or Mental Illness When Data Are Used For Public Reporting As Part Of The Public Comments On Updates To The Health Outcome Survey.

Promoted permanent or long-term extension of SNP legislative authority; Advocated for appropriate Medicare risk adjusted payment methods for SNPs serving high risk populations, including implementing the updated HCC risk adjustment model used for PACE, implementing an individual level frailty adjuster for SNPs, extending the expanded MA supplemental benefit offering to all SNPs, restoring some of the risk factors eliminated by CMS for the 2014 HCC risk adjustment model, evaluating and advocating for adjustments to account for unfunded costs associated with social determinants of health, ensuring that SNPs are not paid less than fee-for-service for beneficiaries eligible for Medicare and Medicaid services, and other matters; Worked toward advancing more appropriate basis for the evaluation and approval of special needs plans, including aligning Model of Care requirements and Structure and Process measures; modifying the Star rating measures to be more relevant to populations served by special needs plans; and risk adjusting or stratifying measures to account for the impact of socioeconomic status on ratings for plans serving disadvantaged populations like dual eligible enrollee Promoted amendment and reintroduction of Sections 101, 102 and 208 of S. 2110 and related sections of S. 2553 to achieve this end; Worked with the Medicare/Medicaid Coordination Office, Congress, and others towards advancing the integration of Medicare and Medicaid benefits for Medicare-Medicaid Enrollees; Advocated changes to the Better Care, Lower Cost Act (S. 1932) to ensure that SNPs are not disadvantaged relative to new health plan models and ACOs; Advocated for changes to proposed rules regarding the release of Medicare Advantage related encounter data to nongovernmental external entities that could use competitively sensitive information to gain unfair advantage over competitors or publish research that may compromise plans competitive positions; Advocated to ensure that Medicare Advantage plans and SNPs would be fully compensated for costs associated with a new high-price drug called Sovaldi that was approved after the 2014 and 2015 Medicare Advantage rates were set; Advocated against the termination of Medicare Advantage special needs plans on the basis of low performing icons and requested that CMS delay the decision to act on termination and to modify the time frame during which plans would be evaluated for performance in relation to termination; Advocated for an evaluation of the reliability of data from self-report survey instruments when completed by persons with cognitive impairment or mental illness when data are used for public reporting as part of the public comments on updates to the Health Outcome survey.

See Next Page for Narrative.Promoted permanent extension of SNP legislative authority which ultimately was enacted under HR 4302, Protecting Access to Medicare Act of 2014 and also was included related legislation including S. 2110, Medicare SGR Repeal and Beneficiary Access Improvement Act of 2014; Advocated for appropriate Medicare risk adjusted payment methods for SNPs serving high risk populations, including implementing the updated HCC risk adjustment model used for PACE, implementing an individual level frailty adjuster for SNPs, extending the expanded MA supplemental benefit offering to all SNPs, restoring some of the risk factors eliminated by CMS for the 2014 HCC risk adjustment model, evaluating and advocating for adjustments to account for unfunded costs associated with social determinants of health, ensuring that SNPs are not paid less than fee-for-service for beneficiaries eligible for Medicare and Medicaid services, and other matters; Worked toward advancing more appropriate basis for the evaluation and approval of special needs plans, including aligning Model of Care requirements and Structure and Process measures and modifying the Star rating measures to be more relevant to populations served by special needs plans; and advancing changes to account for the impact of social determinants of health on plan ratings; Worked with the Medicare/Medicaid Coordination Office, Congress, and others towards advancing the integration of Medicare and Medicaid benefits for Medicare-Medicaid Enrollees; Advocated for changes to the proposed model of care requirements and scoring criteria used by NCQA to evaluate Models of Care for special needs plans; Advocated for changes to the proposed modifications of Chapter 16b regulations governing special needs plans; Advocated for changes to performance evaluation methods for special needs plans and Medicare-Medicaid plans, including risk adjustments to account for the impact of socioeconomic status on ratings for plans serving disadvantaged populations like dual eligible enrollees, and submitted extensive comments to the National Quality Forum in this regard; Advocated for multiple financial, administrative and clinical changes to proposed rule for Medicare Advantage plans; Advocated against proposed changes to the 2015 Medicare Advantage payment methodology that would result in further cuts to Medicare Advantage plans; Advocating changes to the Better Care, Lower Cost Act (S. 1932/HR 3890) to ensure that SNPs are not disadvantaged relative to new health plan models and ACOs.

See Next Page for Narrative.Promote permanent extension of SNP legislative authority, as well as changes to MedPAC recommendations on SNP extension; Advocating for appropriate Medicare risk adjusted payment methods for SNPs serving high risk populations, including implementing the updated HCC risk adjustment model used for PACE, implementing an individual level frailty adjuster for SNPs, extending the expanded MA supplemental benefit offering to all SNPs, restoring some of the risk factors eliminated by CMS for the 2014 HCC risk adjustment model, evaluating and advocating for adjustments to account for unfunded costs associated with social determinants of health, ensuring that SNPs are not paid less than fee-for-service for beneficiaries eligible for Medicare and Medicaid services, and other matters; Advancing more appropriate basis for the evaluation and approval of special needs plans, including aligning Model of Care requirements and Structure and Process measures and modifying the Star rating measures to be more relevant to populations served by special needs plans; and advancing changes to account for the impact of social determinants of health on plan ratings. Working with the Medicare/Medicaid Coordination Office, Congress, and others towards advancing the integration of Medicare and Medicaid benefits for Medicare-Medicaid Enrollees; Advocating changes to the proposed modification of model of care requirements and scoring criteria used by NCQA to evaluate MOCs for special needs plans. Advocating for changes to the proposed modifications of Chapter 16b regulations governing special needs plans. Advocating for the above changes as part of the SGR Repeal and Medicare Beneficiary Access Act of 2013 approved by the Senate Finance Committee in 2013.

See Next Page for Narrative.Promote permanent extension of SNP legislative authority, as well as changes to MedPAC recommendations on SNP extension; Advocating for appropriate Medicare risk adjusted payment methods for SNPs serving high risk populations, including implementing the updated HCC risk adjustment model used for PACE, implementing an individual level frailty adjuster for SNPs, extending the expanded MA supplemental benefit offering to all SNPs, restoring some of the risk factors eliminated by CMS for the 2014 HCC risk adjustment model and other matters; Advancing more appropriate basis for the evaluation and approval of special needs plans, including aligning Model of Care requirements and Structure and Process measures and modifying the Star rating measures to be more relevant to populations served by special needs plans; Working with the Medicare/Medicaid Coordination Office, Congress, and others towards advancing the integration of Medicare and Medicaid benefits for Medicare-Medicaid Enrollees; Advocating changes to the proposed modification of model of care requirements for special needs plans; Advocating for changes to the proposed modifications of Chapter 16b regulations governing special needs plans.

See Next Page for Narrative.Promote permanent extension of SNP legislative authority, as well as changes to MedPAC recommendations on SNP extension outlined in MedPACs March Report to Congress; Advocating for appropriate Medicare risk adjusted payment methods for SNPs serving high risk populations, including implementing the updated HCC risk adjustment model used for PACE, implementing an individual level frailty adjuster for SNPs, extending the expanded MA supplemental benefit offering to all SNPs, modifying application of coding intensity adjustment for plans in relation to populations condition complexity, restoring some of the risk factors eliminated by CMS for the 2014 HCC risk adjustment model and other matters; Advancing more appropriate basis for the evaluation and approval of special needs plans, including aligning Model of Care requirements and Structure and Process measures and modifying the Star rating measures to be more relevant to populations served by special needs plans; Working with the Medicare/Medicaid Coordination Office, Congress and others towards advancing the integration of Medicare and Medicaid benefits for Medicare-Mediciad Enrollees; Advocating for clarifications of proposed Medicare Advantage Medical Loss Ratio Requirements that all Medicare Advantage and SNP specific quality and Model of Care related requirements qualify as activities to improve quality for purposes of calculating a plans MLR; Advocating for modifications of Medicare Managed Care Manual, Chapter 4 changes, to expand supplemental benefit offerings to allow all SNPs to provide as supplemental benefits the type of benefits and services needed to effectively implement their Model of Care mandates; Advocating for clarification of Medicare marketing rules to allow institutional SNPs and their nursing home partners to be permitted to proactively educate nursing home residents and their responsible parties about the potential benefits of an ISNP to meet their health care needs.

See Next Page for Narrative.Promote SNP Extension provisions contained in The American Tax Payers Relief Act, Public Law 112-240 (HR 8); Post Tax Payer Relief Act, which only provided short-term extension of SNP authority, advocating for a permanent extension of SNP legislative authority, as well as changes to MedPAC recommendations on SNP extension presented at MedPACs January 2013 meeting and in their March Report to Congress; Advancing dual integration demonstration projects and other legislative and regulatory pathways for integrating Medicare and Medicaid benefits and services outside of the CMS Medicare Medicaid Coordination Office integration demonstrations, with special emphasis on adequate risk adjusted payment methods for high-risk enrollees; streamlined population-based performance measures aligned with enrollees special needs; and alignment of Medicare and Medicaid administrative requirements. Aligning marketing and enrollment requirements with the characteristics of dual eligibile beneficiaries, including the ability to market Medicare and Medicaid benefits as an integrated benefit package, to exclude confusing references to out of pocket maximum costs for dual eligibles with no cost-sharing obligations and to provide passive renewal of Medicaid eligibility for duals. Advancing better alignment between SNP Model of Care Requirements and SNP performance measures and between SNP population characteristics and quality measures, including more appropriate measures and methods for determining plan ratings for SNPs. Advancing greater use of true outcome measures and . alignment of conflicting and duplicative reporting requirements across Medicare Advantage, Medicaid and SNPs Advocating for greater transparency in the evaluation of SNPs, including access to performance evaluation criteria for quality improvement projects. Advocating for appropriate Medicare risk adjusted payment methods for SNPs serving high risk populations, including implementing the updated HCC risk adjustment model used for PACE, implementing an individual level frailty adjuster for SNPs, extending the expanded MA supplemental benefit offering to all SNPs, modifying application of coding intensity adjustment for plans in realtion to populations condition complexity, assuring appropriate definition of activities to improve quality in MLR and appropriate inclusions and exclusions from numerator and denominator of MLR, and other matters; Advancing more appropriate basis for the evaluation and approval of special needs plans (SNPs) by NCQA; Advocating for Congress to direct CMS to develop 2014 MA payment rates based on an assumption that physician payments would not be cut by 25% in 2014.

See Next Page for Narrative. Advocating for a 3-5 year extension of SNP legislative authority; Advancing dual integration demonstration projects and appropriate roles for special needs beneficiaries with special emphasis on plan selection criteria that ensures capabilities in integrated Medicare and Medicaid care and program integration; protection of high-risk beneficiaries being passively enrolled in demo plans; adequate risk adjusted payment methods for high-risk enrollees; streamlined population-based performance measures aligned with enrollees special needs; and other strategies for maximizing potential for success; Advancing more appropriate measures and methods for determining plan ratings for SNPs, including SNP specific measures, and aligning conflicting and duplicative reporting requirements for Medicare Advantage, Medicaid and SNPs; Advocating for appropriate Medicare risk adjusted payment methods for SNPs serving high risk populations, including implementing the updated HCC risk adjustment model used for PACE, implementing an individual level frailty adjuster for SNPs, extending the expanded MA supplemental benefit offering to all SNPs, and other matters; Advancing more appropriate basis for the evaluation and approval of special needs plans (SNPs) by NCQA; SNP Extension provisions contained in The American Tax Payers Relief Act , Public Law 112-240; HR 8.

See Next Page for Narrative. Advocating for a 3-5 year extension of SNP legislative authority; Advancing dual integration demonstration projects and appropriate roles for special needs beneficiaries with special emphasis on plan selection criteria that ensures capabilities in integrated Medicare and Medicaid care and program integration; protection of high-risk beneficiaries being passively enrolled in demo plans; adequate risk adjusted payment methods for high-risk enrollees; streamlined population-based performance measures aligned with enrollees special needs; and other strategies for maximizing potential for success; Advancing more appropriate measures and methods for determining plan ratings for SNPs, including SNP specific measures, and aligning conflicting and duplicative reporting requirements for Medicare Advantage, Medicaid and SNPs; Advocating for appropriate Medicare risk adjusted payment methods for SNPs serving high risk populations, including implementing the updated HCC risk adjustment model used for PACE, implementing an individual level frailty adjuster for SNPs, extending the expanded MA supplemental benefit offering to all SNPs, and other matters; Advancing more appropriate basis for the evaluation and approval of special needs plans (SNPs) by NCQA; Exploring opportunities to advance each of these issues, and others, as part of the expected Medicare legislation that will be acted upon by Congress during the lame duck session.

See Next Page for Narrative. Advocating for a 3-5 year extension of SNP legislative authority; Advancing dual integration demonstration projects and appropriate roles for special needs beneficiaries with special emphasis on plan selection criteria that ensures capabilities in integrated Medicare and Medicaid care and program integration; protection of high-risk beneficiaries being passively enrolled in demo plans; adequate risk adjusted payment methods for high-risk enrollees; streamlined population-based performance measures aligned with enrollees special needs; and other strategies for maximizing potential for success; Advancing more appropriate measures and methods for determining plan ratings for SNPs, including SNP specific measures, and aligning conflicting and duplicative reporting requirements for Medicare Advantage, Medicaid and SNPs; Advocating for appropriate Medicare risk adjusted payment methods for SNPs serving high risk populations, including implementing the updated HCC risk adjustment model used for PACE, implementing an individual level frailty adjuster for SNPs, extending the expanded MA supplemental benefit offering to all SNPs, and other matters; Advancing more appropriate basis for the evaluation and approval of special needs plans (SNPs) by NCQA; Exploring opportunities to advance each of these issues, and others, as part of the expected Medicare legislation that will be acted upon by Congress during the lame duck session.

See Next Page for Narrative. Advocating for a 3-5 year extension of SNP legislative authority; Advancing dual integration demonstration projects and appropriate roles for special needs beneficiaries with special emphasis on plan selection criteria that ensures capabilities in integrated Medicare and Medicaid care and program integration; protection of high-risk beneficiaries being passively enrolled in demo plans; adequate risk adjusted payment methods for high-risk enrollees; streamlined population-based performance measures aligned with enrollees special needs; and other strategies for maximizing potential for success; Advancing more appropriate measures and methods for determining plan ratings for SNPs, including SNP specific measures, and aligning conflicting and duplicative reporting requirements for Medicare Advantage, Medicaid and SNPs; Advocating for appropriate Medicare risk adjusted payment methods for SNPs serving high risk populations, including implementing the updated HCC risk adjustment model used for PACE, implementing an individual level frailty adjuster for SNPs, extending the expanded MA supplemental benefit offering to all SNPs, and other matters; Advancing more appropriate basis for the evaluation and approval of special needs plans (SNPs) by NCQA; Advancing adjustments to MA marketing rules that impede SNPs ability to effectively target, educate and enroll a subset of the Medicare population, consistent with their legislative mandate; Exploring opportunities to advance each of these issues, and others, as part of the expected Medicare legislation that will be acted upon by Congress during the lame duck session.

See Next Page for Narrative. Worked to avoid cuts to Medicare Advantage Special Needs Plans or cuts to Medicare and Medicaid Innovation Center or CMS Duals Office that would jeopardize dual integration initiatives and delivery reform for special needs populations -- and for ongoing support for dual integration initiatives -- in relation to the Joint Select Committee on Deficit Reductions recommendations to Congress on reducing the debt. Also worked to ensure they did not project huge first year savings from integration programs that could jeopardize long-term solvency and success of the programs; Advancing clear and quantifiable guidance for SNP approval process by NCQA, including guidance regarding criteria and scoring for SNP approval and timely release of such policies; Advancing dual integration demonstration projects with: flexible pathways to full integration of Medicare and Medicaid benefits for states and plans; new patient care models; and new payment and performance methods that are better aligned with beneficiary needs and care models; Advancing more appropriate measures and methods for determining plan ratings for SNPs, including SNP specific measures, aligning the multiple and inconsistent and duplicative reporting requirements for SNPs, reducing data fatigue and improving the overall value proposition of SNP performance measurement; Advocating appropriate Medicare risk adjusted payment methods for SNPs serving high risk populations.

See Next Page for Narrative. Issues related to implementation of PL 111-148 including: Advancing clear and quantifiable guidance for SNP approval process by NCQA, including guidance regarding criteria and scoring for SNP approval and timely release of such guidance; Advancing demonstration projects related to new patient care models and payment models via the Center for Medicare and Medicaid Innovations as a vehicle for alleviating regulatory barriers to managed specialty care programs; Advocating for SNP initiatives with flexible pathways to full integration of Medicare and Medicaid benefits that recognize varying state interests and capacities for implementing fully capitated specialty care programs for duals; Advancing more appropriate measures and methods for determining plan ratings for SNPs, including SNP specific measures, aligning the multiple and inconsistent and duplicative reporting requirements for SNPs, reducing data fatigue and improving the overall value proposition of SNP performance measurement. Advocating three phase approach to improved performance measurement; Modifying NCQA SNP specific performance methods; Ensuring equitable implementation of ACA provisions on frailty adjusted payments for fully integrated special needs plans in relation to PACE plans and timely guidance from CMS on eligibility criteria and related reporting requirements for evaluating eligibility; Advocating for elimination of barriers to integration via CMS Alignment Initiative implemented by Federal Coordinated Health Care Office.

See Next Page for Narrative. Issues related to implementation of PL 111-148 including: Advancing clear and quantifiable guidance for SNP approval process by NCQA, including guidance regarding criteria and scoring for SNP approval and timely release of such guidance; Advancing integrated programs for dually eligible beneficiaries through the new Federal Coordinated Health Care Office; Advancing demonstration projects related to new patient care models and payment models via the Center for Medicare and Medicaid Innovations as a vehicle for alleviating regulatory barriers to managed specialty care programs; Advocating for SNP initiatives with flexible pathways to full integration of Medicare and Medicaid benefits that recognize varying state interests and capacities for implementing fully capitated specialty care programs for duals; Advancing more appropriate measures and methods for determining plan ratings for SNPs, including SNP specific measures, aligning the multiple and inconsistent and duplicative reporting requirements for SNPs, reducing data fatigue and improving the overall value proposition of SNP performance measurement. Advocating three phase approach to improved performance measurement; Modifying the current structure for bonus payments to Special Needs Plans, consistent with the nature of the high-risk populations served and with current CMS and NCQA reporting requirements; Modifying NCQA SNP specific performance methods; Ensuring equitable implementation of ACA provisions on frailty adjusted payments for fully integrated special needs plans in relation to PACE plans and timely guidance from CMS on eligibility criteria and related reporting requirements for evaluating eligibility; Advocating for appropriate implementation of ACA mandate for CMS evaluation of the current MA risk adjustment methodology for specified high risk beneficiaries, consistent with provisions in Public Law 111-148, for MA contract year 2012; Advocating for elimination of barriers to integration via CMS Alignment Initiative implemented by Federal Coordinated Health Care Office; Advocated for revisions to draft Evidence of Benefit forms for dually eligible beneficiaries to eliminate references to cost-sharing and maximum out of pocket costs.

See Next Page for Narrative. Issues related to the ongoing implementation of MIPPA regulations including: Marketing rules related to (1) permissible provider-based activities for institutional SNPs; (2) call center process issues for all SNP types; and (3) outbound verification issues for ISNPs and DSNPs. Variety of contracting issues for D-SNPs related to Medicaid benefit documentation, timeframe for submission of signed Medicaid contracts, lack of consistent communication and guidance from CMS central and regional offices, need for incentives and support for SNP-state managed care partnerships for duals, etc. Issues related to implementation of PL 111-148 including: Advancing clear and quantifiable guidance for SNP approval process by NCQA, including guidance regarding criteria and scoring for SNP approval and timely release of such guidance; Advancing integrated programs for dually eligible beneficiaries through the new Federal Coordinated Health Care Office; Advancing demonstration projects related to new patient care models and payment models via the Center for Medicare and Medicaid Innovations as a vehicle for alleviating regulatory barriers to managed specialty care programs. Advocating for SNP initiatives with flexible pathways to full integration of Medicare and Medicaid benefits that recognize varying state interests and capacities for implementing fully capitated specialty care programs for duals; Advancing more appropriate measures and methods for determining plan ratings for SNPs, including SNP specific measures, aligning the multiple and inconsistent and duplicative reporting requirements for SNPs, reducing data fatigue and improving the overall value proposition of SNP performance measurement. Advocating three phase approach to improved performance measurement. Modifying the current structure for bonus payments to Special Needs Plans, consistent with the nature of the high-risk populations served and with current CMS and NCQA reporting requirements Advocated for SNP specific performance measures for use in overall plan ratings, star ratings and quality bonus payments Ensuring equitable implementation of ACA provisions on frailty adjusted payments for fully integrated special needs plans in relation to PACE plans and timely guidance from CMS on eligibility criteria and related reporting requirements for evaluating eligibility. Advocating for appropriate implementation of ACA mandate for CMS evaluation of the current MA risk adjustment methodology for specified high risk beneficiaries, consistent with provisions in Public Law 111-148, for MA contract year 2012; Advocated for revisions to Chapter 4 of the Medicare Managed Care Manual to effect a more appropriate definition of supplemental benefits and authority to include secondary and tertiary services for special needs beneficiaries in bids under the supplemental benefit category, consistent with SNP requirements to provide add-on services to meet the unique health care needs of the target population served by SNPs.

Issues related to the need for alignment across MA and SNP performance measures developed by CMS and the National Commission on Quality Assurance; Issues related to the ongoing implementation of MIPPA regulations including: marketing rules related to permissible provider-based activities for institutional SNPs, call center process issues contracting issues for D-SNPs related to Medicaid benefit documentation differences in Medicare and Medicaid model of care requirements and related issues; documentation related to warning letters for low-performing plans, etc. P.L. 111-148 issues related to: the role of the new Federal Coordinated Health Care Office; demonstration projects related to new patient care models and payment models being implemented by the new Center for Medicare and Medicaid Innovations; provisions to advance more appropriate measures and methods for determining Star quality bonus payments to Special Needs Plans, consistent with the nature of the high-risk populations served and with current CMS and NCQA SNP specific performance methods; and the new approval process NCQA will be implementing for special needs plans effective 2012; Worked to facilitate fair implementation of ACA provisions on frailty adjusted payments for fully integrated special needs plans effective 2011 and 2012 MA contract year; and to ensure CMS evaluation of the current MA risk adjustment methodology for specified high risk beneficiaries, consistent with provisions in Public Law 111-148, for MA contract year 2012; Issues related to the submission of MA bids, including denials regarding supplemental benefits for services required by CMS for special needs plans, TBC edits, denials of SNPs related to meaningful benefit differences and related issues.

Regulatory issues related to the ongoing implementation of MIPPA regulations including comprehensive written statements of Medicaid benefits and protections, performance measurements for SNPs developed by CMS and the National Commission on Quality Assurance, a broad range of marketing rules including permissible provider-based activities for institutional SNPs, C-SNP validation rules, call center process issues, and related issues; Worked with CMS and NCQA and Congress on the role of the new Federal Health Care Office, the use of Star measures in calculating quality bonus payments for SNPs and the new approval process NCQA will be implementing for special needs plans effective 2012; Worked with Congress and CMS to facilitate implementation of frailty adjusted payments for fully integrated special needs plans effective 2011 MA payment year, consistent with provisions in Public Law 111-148, but contrary to CMS final notice of MA payment changes for contract year 2011; Worked on health care extenders bills, including H.R. 3962, Affordable Health Care for America Act, to provide CMS the authority to modify Medicare Advantage 2011 contract year bids to include physician fee updates in MA payment rates retrospectively, assuming Congress acts on the sustainable growth rate issue before January 1, 2011, and related matters; Continued efforts to advance full integration of Medicare and Medicaid legislation and initiated exploration of alternative statutory authority for special needs plans; H.R.3962, Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010; Worked with CMS on issues related to the submission of MA bids, including denials regarding supplemental benefits for services required by CMS for special needs plans, TBC edits, partial county approvals for compliant networks, denials of SNPs related to meaningful benefit differences, documentation of summary of benefits in relation to MOOP requirements and related issues. Worked with CMS on MIPPA contracting issues for D-SNPs related to Medicaid benefit documentation, differences in Medicare and Medicaid model of care requirements and related issues; documentation related to warning letters for low-performing plans.

Regulatory issues related to the ongoing implementation of MIPPA regulations including comprehensive written statements of Medicaid benefits and protections, performance measurements for SNPs developed by CMS and the National Commission on Quality Assurance, a broad range of marketing rules including permissible provider-based activities for institutional SNPs, C-SNP validation rules, call center process issues, and related issues; Worked with CMS and NCQA on Accountable Care Act implementation issues, Public laws 111-148 and 111-152, including the role of the new Federal Coordinated Health Care Office, the use of Star measures in calculating quality bonus payments for SNPs and the new approval process NCQA will be implementing for special needs plans effective 2012; Worked with Congress and CMS to facilitate implementation of frailty adjusted payments for fully integrated special needs plans effective 2011 MA payment year, consistent with provisions in Public Law 111-148, but contrary to CMS final notice of MA payment changes for contract year 2011; Worked with Congress and CMS to obtain regulatory relief under proposed rules for Policy and Technical Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Programs, under 42 CFR 422.100(f)(4). These rules would have required all MA plans, including special needs plans (SNPs), to establish a maximum out of pocket (MOOP) expense for Medicare A and B services, pay for all Medicare cost sharing in excess of $6,700, and include these costs in their bids. Our focus was on creating exemptions in 2011 MA bids in relation to full benefit dual eligibles and qualified Medicare beneficiaries who have no cost sharing obligations; Worked on health care extenders bills, including H.R. 3962, Affordable Health Care for America Act, to provide CMS the authority to modify Medicare Advantage 2011 contract year bids to include physician fee updates in MA payment rates retrospectively, assuming Congress acts on the sustainable growth rate issue before January 1, 2011, and related matters; Continued efforts to advance full integration of Medicare and Medicaid legislation and initiated exploration of alternative statutory authority for special needs plans; H.R.3962, Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010

Attempted to amend legislation to prevent physician fee cuts -- to obtain Congressional authority for CMS to modify 2011 Medicare Advantage payments related to physician services, consistent with the 2011 physician fee schedule that will result if Congress passes legislation to halt scheduled cuts in physician fees through December 31, 2011. This included HR 4213, the Tax Extenders Act of 2009. Issues related to the implementation of MIPPA regulations including model of care requirements, state contracts for Dual SNPs, comprehensive written statements of Medicaid benefits and protections, performance measurements for SNPs developed by CMS and the National Commission on Quality Assurance, a broad range of marketing rules including permissible provider-based activities, C-SNP validation rules, call center process issues, comprehensive written benefit statement requirements and related issues regarding structure of the summary of benefits, etc.; Worked to incorporate provisions from HR 2758 and S. 1307, "The Medicare Specialty Care Improvement and Protection Act of 2009," into various versions of House and Senate Health Care Reform legislation, including HR 3962, "Americas Affordable Health Choices Act of 2009, S.1796, Americas Healthy Future Act, HR 3590, "The Patient Protection and Affordable Care Act," and HR 4872, Health Care and Education Reconciliation Act Advocated on issues in the health care reform legislation related to SNP extension, improvement of risk adjusted payments for high risk, the structure of the quality bonus payments, establishment of an office on Medicare/Medicaid integration, changes in enrollment policies for SNPs, Dual SNP contracting provisions, the structure of MA benefits for SNPs, SNP certification programs, an exemption of Medicare and Medicaid premiums from the annual health insurance fee included in the Senate bill, the structure of the MA bidding system for SNPs, authority for CMS to include physician fee updates in MA payment rates retrospectively, assuming Congress acts of the sustainable growth rate issue before January 1, 2011, and related matters.

Worked on behalf of SNP Alliance members on various regulatory issues related to the implementation of MIPPA regulations including model of care requirements, a broad range of marketing rules, state contracts for Dual SNPs, comprehensive written statements of Medicaid benefits and protections, performance measurements for SNPs developed by CMS and the National Commission on Quality Assurance, etc; Worked to incorporate provisions from HR 2758 and S. 1307, "The Medicare Specialty Care Improvement and Protection Act of 2009," into various versions of House and Senate Health Care Reform legislation, including: HR 3200 and HR 3962, two different versions of "Americas Affordable Health Choices Act of 2009;" S. 1796, "Americas Healthy Future Act of 2009;" and HR 3590, "The Patient Protection and Affordable Care Act." In particular, the Alliance focused on issues related to SNP extension, improvement of risk adjusted payments for high risk, the structure of the quality bonus payments, establishment of an office on Medicare/Medicaid integration, changes in HR 3200 enrollment policies for C-SNPs, Dual SNP contracting provisions, the structure of MA benefits for SNPs, SNP certification programs, an exemption of Medicare and Medicaid premiums from an annual health insurance fee or excise tax, the structure of the MA bidding system for SNPs and related matters.

Worked on behalf of SNP Alliance members on various issues related to the implementation of MIPPA regulations including model of care requirements, marketing rules, state contracts for Dual SNPs, comprehensive written statements of Medicaid benefits and protections, etc; Worked to incorporate provisions from HR 2758, The Medicare Specialty Care Improvement and Protection Act of 2009, and the House TriCommittee Draft on Health Care Reform into HR 3200, Americas Affordable Health Choices Act of 2009, and with a special focus on issues related to SNP extension, improvement of risk adjusted payments for high risk, the structure of the quality bonus payments, establishment of an office on Medicare/Medicaid integration, changes in HR 3200 enrollment policies for C-SNPs, and related matters. Worked to include provisions from S. 1307, Medicare Specialty Care Improvement and Protection Act of 2009, into the Senate Finance Committee health care reform package. Special focus on issues related to SNP extension, improvement of risk adjusted payments for high risk, the structure of the quality bonus payments, establishment of an office on Medicare/Medicaid integration, structure for MA payment reform for dual eligible beneficiaries in chairmans mark and related matters.

Worked on behalf of SNP Alliance members on various issues related to the implementation of MIPPA regulations; Advocated for changes to 2009 model of care reporting, reviewed and commented on revisions to 2010 SNP application and model of care format; The development and introduction of the Specialty Care Improvement and Protection Act of 2009, HR 2758 and S. 1307, respectively. This legislation would extend statutory authority for special needs plans (SNPs), require CMS to study and refine Medicare Advantage payment methods for high risk populations and advance the integration of Medicare and Medicaid through a CMS office on Medicare/Medicaid integration and the establishment of a special designation for fully integrated dual eligible SNPs. Worked to incorporate provisions from HR 2758 into the TriCommittee Health Care Reform Draft and HR 3200, Americas Affordable Health Choices Act of 2009, and to make certain modifications to the TriCommittee draft in areas such as the structure of the quality bonuses and structure of the MLR for SNPs and changes in enrollment policies for C-SNPs. Worked to include provisions in S. 1307, Medicare Specialty Care Improvement and Protection Act of 2009, as part of the Senate health care reform package. Special focus on incorporating S. 1307 provisions into the Senate Finance Committee Chairmans mark and to obtain support for refinements to MA risk adjustment, as defined by S. 1307. Worked with CMS to establish a specific structure for reporting and documenting MIPPA comprehensive written statement requirements as part of the standard summary of benefits and worked on draft dual eligible contract language consistent with MIPPA requirements for dual-SNPs to have draft contracts; Submitted comments on Medicare managed care rules regarding marketing;

Worked with National Committee for Quality Assurance on new 2009 HEDIS and Structure and Process performance measures for Medicare Advantage Special Needs Plans; Worked with CMS on a series of issues related to implementation of sections 164 ad 165 of HR 6331, the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA), including model of care requirements, Medicaid contracting requirements, impact of marketing rules on SNPs, C-SNP transitions issues, SNP reporting requirements and other SNP specific issues identified in the CMS 2010 MA Call Letter. Advocated for modifications to the CMS Advisory Panel Report on Chronic Condition SNPs to allow plans to target beneficiaries with multiple chronic conditions, consistent with statutory authority, and to expand the number of multiple condition SNPs proposed in draft 2010 Call Letter. Worked to advance provisions in 2009 health reform legislation to improve care for high-risk Medicare and Medicaid beneficiaries, including permanent statutory authority for Special Needs Plans; improvements in risk adjusted payment methods for high-risk beneficiaries; establishment of an office on Medicare/Medicaid integration; and measures to facilitate administrative integration of oversight policies for dually eligible beneficiaries.

Worked with National Committee for Quality Assurance on new 2009 HEDIS and Structure and Process performance measures for Medicare Advantage Special Needs Plans; Worked with CMS to interpret impact of HR 6331, the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA), on SNPs. Speficially addressed Sections 164 and 165 relating to changes in requirements for Special Needs Plans as well as Section 103 relating to Medicare Advantage marketing rules; Submitted extensive comments on Section 422 of CMS 4138-ICF, the interim final rule on MIPPA in areas relating to new SNP rules and MA marketing rules. Submitted separate comments on CMS proposed revisions to agent compensation rules issued in November 2008; Advocated for CMS changes to the Medicare Advantage proposed Bid Pricing Tool to maintain the current approach to cost-sharing so that SNPs would not be forced to charge dually eligible beneficiaries premiums for Part D coverage; Advocated for SNP Alliance interpretation of Congressional intent regarding C-SNP definition in HR 6331 and modifications to the CMS Advisory Panel Report on Chronic Condition SNPs to allow plans to target beneficiaries with multiple chronic conditions, consistent with statutory authority; Worked with CMS and MedPAC to advocate for administrative actions to improve the Medicare Advantage Risk Adjustment Methodology for high cost beneficiaries enrolled in SNPs; Initiated discussions with Congressional staff regarding focus of 2009 health reform legislation and Medicare legislation to facilitate permanent statutory authority for Special Needs Plans; improvements in risk adjusted payment methods for SNPs; establishment of an office on Medicare/Medicaid integration; and measures to facilitate administrative integration of oversight policies for dually eligible beneficiaries.

Worked with National Committee for Quality Assurance on new performance measures for Medciare Advantage Special Needs Plans; Worked with CMS to interpret impact of MIPPA provisions on Special Needs Plans. Worked to obtain permanent statutory for Medicare SNPs in 2009. Garner support for opportunities to advance legislation that would integrate Medicare and Medicaid benefits for the Dually eligible; Promoted enactment of Section 164 of HR 6331, the Medicare Improvement for Patients and Providers Act of 2008, relating to Special Needs Plans and, following enactment to clarify implementation issues related to MIPPA.

1.Working to reauthorize Section 231 of the Medicare Modernization Act to extend and modify authority for Medicare Advantage Special Needs Plans. Proposed free-standing legislation to accomplish this goal, including to modify SNP provisions in Section 431 of HR 3162 and also to modify Sec. 424 of HR 3162 pertaining to improving risk adjusted payments for Medicare Advantage Plans. 2. Advocated for HR 6331, Medicare Improvement for Patients and Providers Act of 2008, Sec. 164, Revisions Related to Specialized Medicare Advantage Plans for Special Needs Individuals. 3. Advocated for HR 6365, Medicare Special Needs Plans Extension and Amendments Act of 2008. 4. Advocated for S. 3101, Medicare Improvement for Patients and Providers Act of 2008, Sec. 164, Revisions Related to Specialized Medicare Advantage Plans for Special Needs Individuals. 5. Worked for changes to S. 3118, Preserving Access to Medicare Act of 2008, Sec. 163, Revisions Related to Specialized Medicare Advantage Plans for Special Needs Individuals.

1.Working to reauthorize Section 231 of the Medicare Modernization Act to extend and modify authority for Medicare Advantage Special Needs Plans. Proposed free-standing legislation to accomplish this goal, including to modify SNP provisions in Section 431 of HR 3162 and also to modify Sec. 424 of HR 3162 pertaining to improving risk adjusted payments for Medicare Advantage Plans. 2. Submitted comments to the Centers on Medicare and Medicaid Services regarding the 45 Day Advance Notice of Methodological Changes in 2009 Medicare Advantage Payment. 3. Submitted comments to the Centers for Medicare and Medicaid Services on the 2009 Call Letter regarding Medicare Advantage contracts for 2009. 4. Submitted comments to National Committee on Quality Assurance regarding proposed performance measures for Medicare Advantage Special Needs Plans. 5. Sent letter to Medicare Payment Advisory Commissoin regarding the need for changes to Medicare Advantage risk adjusted payment methods for Special Needs Plans.

Advocated for enactment of Section 431 of HR 3162, the Children's Health and Medicare Protection Act of 2007, to extend and revise authority for Special Needs Plans; and Section 424 of HR 3162, to improve risk adjusted payment methods for Medicare Advantage Plans. Advocated for Section 108 of S. 2499, the Medicare, Medicaid and SCHIP Extension Act of 2008, which provided for a one year

benefits for the dually eligible -- requirement that CMS share part of it's MA bid savings with state Medicaid agencies to promote state incentives for integration -- request that part of MA bid savings be incorporated into a pay for performance pool to reward plans meeting new performance standards -- establishment of requirement that SNPs provide complex care management services and report to CMS on specific chronic care performance measures. Working toward reauthorization of Medicare Advantage Special Needs Plans and enhancements, including enactment of HR3162: - requesting 3 year extension of SNP authority - refinement of MA risk adjustment methods by 2010 to pay more accurately for high risk beneficiaries - establishment of CMS Office on Medicare and Medicaid Services to promote better coordination of Medicare and Medicaid

1. Worked primarily with the Centers for Medicare and Medicaid Services (CMS) to clarify rules related to Medicare Advantage Special Needs Plans (SNPs) that were authorized under Sec. 231 of the Medicare Modernization Act of 2003. 2.Encouraged CMS to ensure equitable payment for SNPs in relation to fee-for-service by continuing to apply some type of frailty adjusted payment factor to the HCC risk adjustment methodology as well as other refines to the HCC risk adjuster that would enhance the accuracy of payment for high risk beneficiaries. 3. Encouraged CMS to enact polities that would allow SNPs serving dually eligible beneficiaries to integrate administrative functions, financing and care delivery structures; .e.g, allow plans to integrate marketing, enrollment, appeals and quality reporting functions to create a uniform administrative structure for plans and simplified access and paperwork for beneficiaries. 4. Submitted Comments to CMS on a polity to allow SNPs to specialized in serving a subset of the Medicare population such as frail elderly or adults with disabilities so that demonstrations could transition to SNPs with the same program focus as under demonstration and new SNPs could also targeted services toward specific subsets of the Medicare population. 5. Encouraged CMS to continue working toward the development of new performance measures for SNPs that focus on plan performance in relation to the type of interventions needed by people ;with severe and disabling chronic conditions. 6.Submitted Comments on the 2008 MA-SNP Application form and requested that CMS develop a form for plans serving the dually eligible that would enable them to submit integrated applications, benefit packages and bids. 7. Sent recommendations to CMS regarding SNP surveys for the Report to Congress on SNPs due 12/31/07. 8. Encourages CMS to allow greater flexibility on the treatment6 of supplemental benefits in the development of bids for SNPs. 9, Met with Congressional staff from various House and Senate offices to encourage them to promote equitable payment for SNPs, integration of Medicare and Medicaid programs for SNPs serving duals and appropriate performance measures for SNPs. Did not work with Congressional offices on specific legislation. NHPG conducted on Medicare and Medicaid policy as follows: