Medicare Payment Policy

integrating Medicaid benefits. We found exceptions under two D–SNP models
in which an incentive exists to clinically and financially integrate with Medicaid
benefits. Under one model, a single plan—the D–SNP—covers some or all
Medicaid long-term care services and supports (LTSS), behavioral health
services, or both through its contract with the state. Under another model, a
managed care organization administers the D–SNP and the Medicaid plan
that furnishes some or all of the LTSS or behavioral health services. There is
overlap in the dual-eligible beneficiaries who are enrolled in both plans. Under
this model, integration occurs at the level of the managed care organization
across the two plans. A number of administrative misalignments act as barriers
to integrating Medicare and Medicaid benefits. Most of these barriers—the
inability to jointly market the Medicare and Medicaid benefits that D–SNPs
furnish, multiple enrollment cards, and lack of a model contract for states to
use as a reference—can be alleviated by the Secretary of Health and Human
Services. Aligning the Medicare and Medicaid appeals and grievances
processes, however, would require a change in statute. ■
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