The Medicare-Medicaid Coordination Office at CMS recently released final enrollment guidance for the dual eligible financial alignment demonstration projects that are being planned by about 20 states. The guidance sets standards for passive and voluntary enrollment, including notice requirements. It contains a model application form and 30 different model notices to beneficiaries. It also discusses various disenrollment scenarios. The guidance sets uniform minimum requirements across states but is designed so that state-specific requirements can be added. The text of notices also can be modified, with CMS approval, to reflect state differences.

Advocates working with their states on the dual eligible demonstrations should familiarize themselves with the enrollment guidance. The guidance sets forth the flexibilities that CMS provides to states on designing and operating an enrollment system. Advocates need to ensure that when states add state-specific elements to their versions of the guidance, they lay out all the consumer protections that advocates have worked for in the enrollment process. Advocates should also review the model application form and notices to determine what changes are needed to reflect their state's proposal. Further, they should consider what changes could be made to improve the clarity of the notices and whether the notices need to be revised to meet state requirements for grade-level readability.  

 

To assist advocates, NSCLC created a summary of the elements of the guidance with most impact on beneficiaries.