Commonwealth Coordinated Care Update

An issue identified recently that may have significant implications for dual eligible resident populations in nursing facilities focuses on a provision in the three-way contract between the Centers for Medicare and Medicaid Services (CMS), the Department of Medical Assistance Services (DMAS) and the three contracted health plans (Medicare-Medicaid Plans or MMPs) that stipulates that beneficiaries with other insurance coverage are not eligible to participate in the Commonwealth Coordinated Care (CCC) program.  It is not uncommon for nursing facility residents to have Medicare supplemental insurance policies.  DMAS has indicated that traditional Medigap and Tricare policies indeed meet these criteria.  One primary concern related to this provision is that DMAS and its enrollment broker MAXIMUS do not maintain records that identify which dual eligible beneficiaries have supplemental insurance in effect.  Facilities are encouraged to identify residents with this type of coverage and communicate and clarify the CCC participation restriction to residents, resident’s families or their representatives with this coverage.

As previously reported, the CCC enrollment broker recently mailed letters to all identified dual eligible beneficiaries announcing the new managed care program.  Unfortunately, the beneficiary letters do not provide significant guidance to beneficiaries about their option to opt-out of the CCC and to remain covered under both traditional Medicare and Medicaid fee-for-service programs.  As patients and residents and their families or representatives seek additional information about the CCC, it is important that they be made aware of this option.  Eligible beneficiaries may opt-out of the CCC by calling MAXIMUS at 855.889.5243.

During the month of May, Maximus is scheduled to begin the automatic (passive) enrollment process for all identified dual eligible beneficiaries in the Tidewater region.  Coverage and payment for services provided to those CCC Tidewater enrollees will begin July 1, 2014. The implementation schedule is provided below for all five CCC regions.

Tidewater area:

March 2014:   Voluntary enrollment begins
April 2014:     Services/supports begin for those enrolled
May 2014:      Automatic enrollment begins
July 2014:       Services/supports for those automatically enrolled begins

Central Virginia/Richmond area:

March 2014:     Voluntary enrollment begins
April 2014:       Services/supports begin for those enrolled
June 2014:        Automatic enrollment begins
August 2014:    Services/supports for those automatically enrolled begins

Northern Virginia, Roanoke, Charlottesville areas:

May 2014:         Voluntary enrollment begins
June 2014:        Services/supports begin for those enrolled
August 2014:    Automatic enrollment begins
October 2014:  Services/supports for those automatically enrolled begins