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DOH Releases Draft FIDA Phase-Out Plan for Comment

The Department of Health (DOH) has released a draft plan for the phase-out of the Fully Integrated Duals Advantage (FIDA) demonstration program, which expires on Dec. 31, 2019. The draft phase-out plan is open for public comment until July 26th and will be submitted to the Centers for Medicare and Medicaid Services (CMS) by Aug. 5th, with anticipated approval by Aug. 19th and implementation to commence by Aug. 26th. There are currently 2,706 FIDA participants.

The phase-out plan documents various operational and policy aspects of the transition. DOH has asked CMS to allow it to enroll all FIDA beneficiaries in the Medicaid Advantage Plus (MAP) plan and the associated Medicare Advantage Dual-Eligible Special Needs Plan (D-SNP) (hereafter referred to as a “MAP-participating D-SNP”) owned by the same parent organization that administers their FIDA plan. The passive enrollment process would enable FIDA beneficiaries to continue receiving integrated care and care coordination of their Medicare and Medicaid benefits under the auspice of the same parent organization. Beneficiaries would have the opportunity to choose a different Medicare Advantage plan, Original Medicare, a Program of All-Inclusive Care for the Elderly (PACE), and/or a new partially-capitated Managed Long Term Care (MLTC) plan. All FIDA plans currently offer, or are in the process of soon offering, MAP-participating D-SNPs.

CMS is currently considering whether to allow this passive enrollment of FIDA beneficiaries into the associated MAP and D-SNP plans based on the following requirements:

  • Existing Medicare providers for the FIDA plan and MAP-participating D-SNP must be comparable;
  • Medicare benefits between the FIDA plan and MAP-participating D-SNP must be similar;
  • Premium and cost-sharing between the FIDA plan and MAP-participating D-SNP must be similar; and
  • Medicare payment for the MAP-participating D-SNP must be less than or equal to the Medicare fee-for-service rate.

FIDA plans that meet the above requirements in a particular county will be eligible for passive enrollment of their FIDA beneficiaries in that county into that organization’s MAP-participating D-SNP for the same county.

FIDA plans will send disenrollment/transition letters to members no later than 90 days prior to the plan’s termination date (i.e., Oct. 2, 2019 for a Dec. 31, 2019 termination). FIDA beneficiaries who are eligible for passive enrollment will be enrolled into the aligned MAP plan and MAP-participating D-SNP in the fall of 2019. Individuals who are not eligible for passive enrollment into a MAP-participating D-SNP and who do not elect to change their coverage during 2019 will be enrolled into a partially-capitated MLTC plan effective Jan. 1, 2020.

The phase-out plan also includes information concerning beneficiary transitions, continuity of care, enrollment responsibilities and timelines, beneficiary notices and supports, customer service scripts, and ongoing stakeholder engagement. The draft phase-out plan is available here. Scripts for informing beneficiaries about the transition are available here and here.

Comments on the phase-out may be submitted here by July 26th.

Contact: Karen Lipson, klipson@leadingageny.org, 518-867-8383 ext. 124