| On April 22nd, CMS posted online a new proposed rule that includes several provisions related to dually eligible beneficiaries and would impact states, including proposals to (a) limit retroactive Medicare Part B premium liability for states to 36 months, (b) retire the old stand-alone buy-in agreements and specify that the provisions of a state buy-in agreement shall be set forth in the states Medicaid state plan, and (c) extend the Medicare Savings Programs (MSPs) to cover premiums and cost sharing for individuals enrolling in the new Medicare immunosuppressive drug benefit. The proposed regulations would also create a new Medicare special enrollment period (SEP) for individuals losing Medicaid eligibility once normal operations resume after the end of the COVID-19 public health emergency and who did not enroll in Medicare on time. The most salient content begins under the section headers SEP to Coordinate with Termination of Medicaid Coverage, Modernizing State Payment of Medicare Premiums, and Ensuring Coverage under the Medicare Savings Programs. We encourage you to review this proposed rule and provide comments through the formal comment process. We will also provide an overview of the key provisions of this proposed rule to states in the coming weeks. | 
