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We are writing to call state attention to the release of the Contract Year 2025 Medicare Advantage and Prescription Drug Proposed Rule (CMS-4205-P). We encourage states to review the entire proposed rule, but some proposals of particular interest to states are under the following headers:

• Increasing the Percentage of Dually Eligible Managed Care Enrollees Who Receive Medicare and Medicaid Services from the Same Organization. Proposals would
• Replace the current quarterly special enrollment period (SEP) with a one-time-per month SEP for dually eligible individuals and others enrolled in the Part D low-income subsidy program to elect a standalone PDP;
• Create a new integrated care SEP to allow dually eligible individuals to elect an integrated D-SNP on a monthly basis;
• Limit enrollment in certain D-SNPs to those individuals who are also enrolled in an affiliated Medicaid MCO; and
• Limit the number of D-SNPs that organizations can offer in certain circumstances
  
• Contracting Standards for Dual Eligible Special Needs Plan Look-Alikes, which would lower the current threshold for identifying D-SNP look-alikes
  
• Expanding Permissible Data Use and Data Disclosure for MA Encounter Data, which would expedite state access to MA encounter data for care coordination for dually eligible individuals
  
• For D-SNP PPOs, Limiting Out-of-Network Cost Sharing, which would reduce state liability for Medicare cost sharing in certain instances
  
• Update to the Multi-Language Insert Regulation

The proposed rule also includes three comment solicitations that may be of particular interest to states:

• Medicare Plan Finder and Information on Certain Integrated D-SNPs
• State Enrollment Vendors and Enrollment in Integrated D-SNPs
• Use of MA Encounter Data to Support Required Medicaid Quality Reporting

Please review the full proposed rule for more information. The press release and fact sheet can be found at: Press Release and Fact Sheet. We encourage states to review and comment by the deadline, January 5, 2024.

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