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CHA Comments on DHCS Proposal to Expand Access to Integrated Care for Dual-Eligible Californians

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Last week, CHA submitted comments to the Department of Health Care Services (DHCS) on its proposal to discontinue Cal MediConnect and the Coordinated Care Initiative and transition to a statewide managed long-term services and supports (MLTSS) and dual eligible special needs plan (D-SNP) structure.

Titled Expanding Access to Integrated Care for Dual Eligible Californians, the proposal was released as part of the California Medi-Cal Healthier California for All initiative, the state’s multi-year initiative to redesign the Medi-Cal delivery system. It aims to promote integrated care through D-SNPs and MLTSS plans across California. This includes mandatory enrollment for dually-eligible individuals into MLTSS plans and increasing the availability of D-SNPs, which would allow the dually eligible to voluntarily enroll in the D-SNP aligned with their MLTSS plan.

In its letter, CHA supports the move to standardize policies and procedures addressing long-term services and supports, long-term care, and D-SNPs throughout the state, and agrees that these changes could support streamlined plan oversight, as well as greater consistency in care services. CHA notes that the experience of California’s hospitals and post-acute care providers under the current system has shown many opportunities to improve care coordination for this vulnerable population. The letter outlines recommendations in the following areas:

  • D-SNP integration requirements
  • Selective contracting with D-SNPs
  • D-SNP grievance and appeal requirements
  • Medi-Cal managed long-term services and supports
  • Mandatory enrollment into Medi-Cal managed care plans
  • Enrollment considerations and consumer protections
  • Reporting requirements, oversight, and quality
  • Alignment of D-SNP and companion Medicaid plan service area
  • Transition and enrollment policies
  • Interaction with other parts of the health care system, including health-related initiatives