Medicare Part D and Dual Eligibles

Executive Summary

Sign-on letter recommending "Readiness Criteria" to serve as a pre-implementation check-list of items critical to ensuring that participating health plans are prepared to serve the dual eligible population.

Our respective organizations have previously testified and submitted our written concerns with  respect to the Duals Demonstration ? Coordinated Care Initiative, which would integrate  Medicare and Medi-Cal services for persons who are dually eligible for those programs. For  your convenience, we have developed the following ?Readiness Criteria? to serve as a preimplementation check-list of items that we believe are critical to ensuring that participating health plans and the State are prepared to serve the dual eligible population. The State should have the following completed six months prior to (unless otherwise noted) the commencement  of enrollment of dual eligibles in the demonstration counties, and should submit to the  Legislature, and post on the DHCS website, evidence that these tasks have been completed.
Outreach to Consumers:

  1. Contract in place and funding for plan comparison and ?choice counseling? by an independent entity (eg. HICAP or Health Consumer Center) that is adequately funded to assist the population of beneficiaries who will be asked to make decisions on their options to participate in the demonstration or to receive their care elsewhere.
  2. Design of all enrollment-related notices, including summary of benefits, evidence of coverage, prescription formulary, provider directory, etc. as well as all appeals related notices produced in coordination with existing CMS guidelines. All notices will have been vetted by stakeholders.
  3. Contracts are entered into with entities for the provision of enrollment information, other notifications, and personal health records in alternative formats (e.g., Braille, large font, CD), plain language, and Medi-Cal threshold languages to persons with various disabilities and Limited English-speaking (LEP) persons, and methodologies have been developed for the prior identification of individuals with these effective communication needs, as well as for meeting alternative format, LEP and plain language requests made after standard print materials have been sent.1
  4. Establishment of marketing rules around the demonstrations, including rules about how non-demonstration plans market to potential demonstration participants and review of plan marketing materials.
  5. Comprehensive outreach plan for beneficiary and provider outreach, including specific materials for persons in nursing and group homes and their families and nursing and group home providers.
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