Commonwealth Coordinated Care Update

Earlier this week, the Department of Medical Assistance Services (DMAS) released its April 2014 update covering the rollout of the Commonwealth Coordinated Care (CCC) program.  As of March 31st, a total of 1,417 individuals voluntarily enrolled in CCC in the Tidewater and Richmond/Central regions.  These voluntary enrollments represent 3.5% of the total Dual Eligible beneficiaries that reside in the two CCC regions.  Of the 1,417 voluntary enrollments, DMAS has indicated that only 14 beneficiaries are receiving services in nursing facilities.  Coverage for those who enrolled prior to March 26th began April 1, 2014.  

The CCC enrollment broker, MAXIMUS, began taking opt-in and opt-out requests by phone Monday, March 3.  MAXIMUS is also processing written enrollment applications and sends the appropriate CMS-approved letters to beneficiaries. Through the end of March, DMAS reports that MAXIMUS has received a total of 1,329 opt-out requests. The MAXIMUS CCC customer service center number is (855) 889-5243 (TTY number for the hearing impaired is (800)-817-6608).  Finalized MMP comparison charts are available on the MAXIMUS website.  

In their March update, DMAS highlights that the decision to opt-in or opt-out of the CCC Program is solely that of the beneficiary and their authorized designee.  Decisions to opt-in or opt-out of the CCC Program are only accepted from the CCC individual or their authorized designee.  Opt-out decisions are only accepted by telephone through the enrollment broker, MAXIMUS.  Written opt-outs are not accepted to ensure the CCC eligible individual has received adequate information about the CCC Program and is experiencing no undue influence while making their choice.  Providers who encourage their care recipients to opt-out of the CCC program because they have decided not to contract with the CCC MMPs are violating beneficiary choice and Federal Code 42 CFR 483.10(a) Exercise of Rights and 42 CFR 483.10(d) Free Choice.  Conversely, 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.  

DMAS and the Centers for Medicare and Medicaid Services (CMS) receive regular updates on network adequacy for CCC service regions and network development is an ongoing process during CCC implementation.  Initial evaluations identified that Humana met network standards in the Mecklenburg area and therefore, initial letters were mailed to CCC eligible individuals in Mecklenburg offering opportunity to opt-in to CCC.  Subsequent evaluations found the network failed to meet the adequacy criteria and does not meet Medicare standards.  As a result, implementation in the Mecklenburg region is delayed.  

We again remind our members that 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), DMAS and MMPs that stipulates that beneficiaries with other insurance coverage are not eligible to participate in the CCC program. DMAS has indicated that traditional Medigap and Tricare policies indeed meet these criteria.  We have requested that DMAS issue a guidance communication to providers clarifying the issue of supplemental insurance coverage.  Unfortunately, neither DMAS nor its enrollment broker MAXIMUS 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.

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. Future CCC Townhalls are scheduled as follows:

Richmond Area Townhall:
Wednesday, April 30, 2014
10:00 am - 12:00 pm Enrollee/Advocate Session
12:00 pm - 2:00 pm Provider Session
Comfort Inn Conference Center
3200 West Broad Street
Richmond, VA 23230

Northern VA Townhall:
Thursday, May 15, 2014
10:00 am - 12:00 pm Provider Session
1:00 pm - 3:00 pm Enrollee/Advocate Session
Fairfax Government Center
12011 Government Center Pkwy
Fairfax, VA 22035

Roanoke Region Townhall:
Tuesday, May 20, 2014
11:30 am - 1:00 pm Provider Session
1:30 pm - 3:30 pm- Enrollee/Advocate Session
Carilion Stonewall Jackson Hospital
1 Health Circle
Lexington, VA 24450

Each of the Medicare-Medicaid Plans is posting its own provider education opportunities on their websites: