CCC Update: CMS Announces Optional Two-Year Extension to the Demonstration

On July 16, the Centers for Medicare and Medicaid Services (CMS) issued a memo to states operating, or in the process of implementing, a Financial Alignment Demonstration, known commonly as a Duals Demonstration or in Virginia, the Commonwealth Coordinated Care (CCC) program.  This CMS memo offered assistance to “interested states to extend the scheduled end dates for each demonstration by two years.”  To request such an extension, states are required to submit a letter of intent by September 1.  While the Virginia Health Care Association (VHCA) has not heard any explicit decision by Virginia’s Department of Medical Assistance Services (DMAS) in regards to requesting an extension for CCC, we suspected that DMAS was involved in these discussions, as DMAS staff has alluded to the possibility of extending the timeframe for CCC in various recent discussions on the future of managed long term care.

Under the original demonstration timeline, the demonstration was scheduled to end on December 31, 2017. It was not yet clear if the CCC “model” would be allowed as a permanent delivery system approach for dual beneficiaries.  Based on the CMS memo, it appears Virginia could opt to extend the CCC program through December 2019, simply through modification to the existing Medicare/Medicaid Plan (MMP) contracts.  The CMS memo does state that “effectuating a change in the scheduled end dates of the demonstrations will be contingent on demonstrated ongoing stakeholder engagement”, but the memo is not clear on any specifics regarding that engagement.

VHCA does have concern that CMS has announced the opportunity for a two-year extension prior to fixing the ongoing CCC implementation issues and determining the relative success of the program through the required evaluation.  VHCA remains committed to working through these CCC issues and has expressed to the Commonwealth that it not expand or extend the CCC program until these issues are resolved.