CVS Health Comments on Medicare and Medicaid Information Collection Activities

WASHINGTON, Dec. 20 -- Melissa Schulman, senior vice president for government and public affairs at CVS Health, Woonsocket, Rhode Island, has issued a public comment on the Centers for Medicare and Medicaid Services' notice entitled "Agency Information Collection Activities; Proposals, Submissions, and Approvals". The comment was written and posted on Dec. 17, 2019:

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Thank you for the opportunity to submit comments on the proposed Applicable Integrated Plan Coverage Decision Letter (CMS-10716; OMB control number: 0938-New), published in the Federal Register on October 18, 2019.

CVS Health is the nation's premier health innovation company helping people on their path to better health. Whether in one of its pharmacies or through its health services and plans, CVS Health is pioneering a bold new approach to total health by making quality care more affordable, accessible, simple and seamless. CVS Health serves an estimated 39 million people through traditional, voluntary and consumer-directed health insurance products and related services. In combination with CVS Health's 9,800 retail locations, approximately 1,100 walk-in medical clinics, leading pharmacy benefits manager with approximately 93 million plan beneficiaries, and expanding specialty pharmacy services, our unique health care model increases access to quality care in all settings, delivers better health outcomes and lowers overall health care costs.

Through Aetna Dual Eligible Special Needs Plans (D-SNPs), we serve over 25,000 dual eligible members in 9 states, and we will be expanding our footprint to 14 states in 2020. We provide personalized, holistic and local care management to all members in our D-SNPs by supporting each member with a dedicated care team staffed by a consistent group of professionals.

We welcome the Administration's ongoing work to promote coordinated care for individuals who are dually-eligible for Medicare and Medicaid. Through our Medicare-Medicaid Plans (MMPs) in Ohio, Illinois and Michigan, we have learned firsthand the opportunities and challenges with integrated models. As such we offer the following comments on the proposed Applicable Integrated Plan Coverage Decision letter.

We applaud the simplicity of the proposed letter because it includes the necessary information our members need to understand the coverage decision without requiring extra information that could potentially confuse members. This is in contrast to the grievance/appeals letter required by our MMPs. Each state has added different requirements to the MMP letter, making it more complex for plans and members. As such, we encourage CMS to use this letter as the template for other integrated plan models such as the MMPs. This would simplify the letters required for MMPs and promote consistency of grievance/appeals letters across integrated models.

Because of the easy-to-understand format of this proposed letter, we recommend that CMS require this template to be used for applicable integrated plans across states without changes or additions by states. States should not add elements to this letter as it would complicate a simple and straightforward letter. It would also be administratively burdensome to use different templates in different states. We appreciate the need for state flexibility but believe communication to members about services should be uniform across states.

We have once specific concern with the proposed letter. The form instructions specify that the 3rd paragraph of the letter, which explains why the plan made the coverage decision, should include the contact information for the covering payer if the Medicaid service is covered by another payer. This requirement to include the contact information of the covering payer will be burdensome and difficult to implement because plans would need access to continually updated contact information for the covering payer for members, likely obtained from the state agency. We are concerned about the feasibility of this requirement given challenges associated with receiving timely, updated contact information for the covering payer for each member.

We also feel that including both the payer information and the offer to help, which would be two different contacts, might result in confusion and frustration for the member. The confusion might stem from which contact to use, along with the possibility that members might expect coverage from the contact listed for help. The frustration might occur if the member tries to contact the Medicaid payer on his/her own, only to discover the payer information had not been updated or the Medicaid payer requires the member to complete an unanticipated step for coverage. As such, we believe including one contact, instead of two, would simplify the member's navigation of this process for a better member experience.

Therefore, we recommend the proposed letter require plans to direct members to their care managers to help them navigate coverage from another payer, instead of including contact information for the covering payer. Care managers are best equipped to understand members' needs and can provide individualized support to help members navigate another payer. In addition, directing the member to the care manager is consistent with the instructions included in our unified grievance and appeals letters that we send members in our MMPs. Changing this requirement will not only be easier for the member, it will support care managers in their objective to provide personalized assistance to each member.

CVS Health is committed to working with CMS to formulate rules and policies that advance coordinated care for dual-eligible members. We believe all dual-eligible members deserve the opportunity to have coverage that seamlessly provides Medicare and Medicaid services. We would be happy to respond to any follow-up questions you may have.

TARGETED NEWS SERVICE, Harwood Place, Springfield, Virginia, USA: Myron Struck, editor; 703/304-1897; [email protected]; https://targetednews.com