Dual Eligibles

With support from Kaiser Permanente and investment firm Town Hall Ventures, Habitat Health has established a new Program of All-Inclusive Care for the Elderly (PACE) provider. Offering comprehensive care to adults who wish to live independently in their homes and communities, Habitat Health will serve aging and low-income adults in California in partnership with Kaiser and eventually expand to other states with local care partners. Habitat Health plans to begin serving PACE-eligible individuals in Los Angeles and Sacramento in 2025 and will serve as payer for all participants’ Medicare and Medicaid services. The new PACE provider will “benefit from Kaiser Permanente’s expertise in creating efficient systems and developing innovative technology to integrate complex care, and from Town Hall Ventures’ experience building successful care delivery companies that support underserved communities,” stated a March 27 press release from all three entities. Town Hall Ventures, whose leadership includes former CMS Acting Administrator and White House adviser Andy Slavitt, was founded in 2018 and has invested in or participated in the launch of 35 health care companies, including Cityblock Health, Landmark Health, Signify Health and VillageMD.

When it comes to aging in place, seniors in the U.S. have a hodgepodge of programs and services available to them, and health plans can be a connector to and integrator of those services in their respective markets. Speakers at AHIP’s 2024 Medicare, Medicaid, Duals & Commercial Markets Forum, held March 12 to 14 in Baltimore, agreed that health plans can also play a valuable role in driving innovations across the Medicare and Medicaid programs, such as providing emergency and acute care in the home, supporting family caregivers, and advocating for policy solutions.

Before CMS in 2020 introduced the Hospital Without Walls program enabling health systems to provide acute hospital care in the home, integrated insurer-provider Kaiser Permanente (KP) launched the Advanced Care at Home (ACAH) model. One of several KP initiatives that support aging in place, ACAH leverages expert care teams and technology to provide 24/7 physician-led acute care and coordinate patients’ recovery in the familiar setting of the home. Eligible patients are identified in urgent care, emergency and/or inpatient settings but must also meet certain social and clinical criteria, explained Rachna Pandya, regional strategic implementation leader of Medicare operations and strategy, during the session, “Best Practices to Support Aging in Place.”

After circulating a discussion draft in the first half of 2023, Sen. Bill Cassidy, M.D. (R-La.) on March 14 released his long-awaited bipartisan bill aimed at improving coverage for Medicare-Medicaid dual eligibles. The Delivering Unified Access to Lifesaving Services Act of 2024 calls for comprehensive changes to the way states and plans currently deliver care to dual eligibles, who often have multiple chronic conditions and account for a disproportionate share of spending.

The bill was introduced by Cassidy and his cosponsors, Sens. Tom Carper (D-Del.), John Cornyn (R-Texas), Mark Warner (D-Va.), Tim Scott (R-S.C.) and Bob Menendez (D-N.J). It would, among other things, require all states to establish an “integrated health plan” for duals — either building off their own or existing options — and require managed care organizations to develop and update comprehensive care plans that include a designated care coordinator for each beneficiary. The legislation also includes “passive enrollment” of qualifying dual eligibles into such plans and continuity of care requirements. The legislation also seeks to expand access to Programs of All-Inclusive Care for the Elderly (PACE) to individuals aged 55 and older.

Starting with the 2027 Star Ratings, CMS will begin rewarding Medicare Advantage plans for their efforts to assess social risk factors and address disparities in certain quality measures with the new Health Equity Index (HEI). Not all plans will qualify and only a third of top-performing plans will be rewarded, but the time is now for plans to look at how they are doing on the claims-based measures that will be impacted and how they are performing for members with one of the qualifying factors (i.e., eligible for Medicare and Medicaid, disability and/or the Part D low-income subsidy).

During a recent panel moderated by AIS Health, a division of MMIT, speakers at the 7th Annual Medicare Advantage Leadership Innovations forum discussed best practices for assessing members’ social needs and how plans can use data to address them and move the needle forward on health equity.

While major Medicare Advantage insurers are bracing for potential revenue reductions stemming from upcoming changes to the risk adjustment model, three insurers presenting at their recent investor conferences appeared bullish on the prospect of continued growth in MA, and in particular, the sizable opportunity to serve people who are dually eligible for Medicare and Medicaid. According to a recent analysis from AIS’s Directory of Health Plans, roughly 5.6 million out of an estimated 13 million dual eligibles in the U.S. are enrolled in a Dual Eligible Special Needs Plan (D-SNP).

Although managed Medicaid and the exchanges remain its No. 1 and 2 revenue drivers, Centene Corp.’s MA business — which has a large concentration of D-SNP members — will be an “important growth driver for Centene long term,” CEO Sarah London told investors on Dec. 12.

Leading up to the 2024 Annual Election Period (AEP) that started on Oct. 15 and concluded on Dec. 7, major Medicare Advantage insurers unveiling geographic expansions signaled their continued pursuit of dually eligible Medicare-Medicaid beneficiaries. A new analysis of the 2024 Special Needs Plan landscape confirms that more SNPs designed specifically for dual eligibles will be available next year, while interest in Institutional SNPs (I-SNPs) appears to be waning after experiencing a short burst of growth. The Chronic Condition SNP (C-SNP) market, meanwhile, will remain relatively stable.

There will be 1,368 SNPs on the market in 2024, up from 1,320 in 2023 — a modest increase compared with the 10% jump between 2022 and 2023, according to the analysis from Clear View Solutions, LLC. Within the total, however, Clear View observed a notable increase in the number of D-SNPs. In 2024, there will be 874 D-SNPs available — including 698 plans that were available in 2023 and 176 new plans — compared with 809 in 2023 and 401 in 2018, before the Bipartisan Budget Act (BBA) of that same year granted permanent authorization to all SNP types. There are also more D-SNPs being added than dropped next year, which could be due to some plan consolidation, observes Clear View.

From 2017 to 2023, the number of people enrolled in Special Needs Plans (SNPs) grew by more than 150% to about 6.3 million lives, according to the latest update to AIS’s Directory of Health Plans. Dual Eligible SNPs (D-SNPs) saw the most growth, a mammoth 170% increase to 5.6 million lives, followed by Institutional SNPS (I-SNPs) at 86% growth, then Chronic Condition SNPs (C-SNPs) at 58% growth.

Payers have grown to meet that surge, with the total number of SNP offerings expanding from 498 to 1,082 plans between 2017 and 2023, per an analysis of CMS’s Landscape files from Clear View Solutions, LLC. Clear View’s data shows that in a typical year, the number of new SNP offerings has exceeded the number of plans dropped.

With the Oct. 1 start of marketing for the 2024 Annual Election Period (AEP), several major publicly traded insurers have unveiled somewhat slower plans for geographic expansion than in previous years, while CMS’s 2024 MA and Part D landscape files suggest that premium increases were a common way to offset potential rate cuts. But according to recent press releases unveiling product enhancements for next year, insurers appear to be extending enhanced supplemental benefits to the broader MA population while offering Dual Eligible Special Needs Plan (D-SNP) beneficiaries greater flexibility to address nonmedical needs.

Trends emerging from early analyses of CMS’s 2024 Medicare Advantage and Part D “landscape files” include a lower concentration of $0 premium plans, increases in monthly premiums by some of the biggest insurers, and less aggressive but continued expansions into new service areas. But industry observers caution against reading too much into the data, given the nuances of benefit design that are not detectable from the landscape files. That said, it’s clear the major publicly traded insurers made a few tradeoffs in order to maintain benefit stability and remain competitive amid financial headwinds.

Insurers reporting second-quarter 2023 earnings earlier this year said they factored the emerging trend of increasing utilization into MA bids that were due in June. Also impacting pricing for next year’s offerings is the phasing in of substantial revisions to the CMS-Hierarchical Condition Categories (HCC) risk adjustment model that could reduce payments depending on plan type and coding practices, along with certain Part D changes resulting from the Inflation Reduction Act (IRA) that increase the cost burden for plans in the catastrophic phase of the benefit.

Supplemental benefits are popular among Medicare Advantage members, but they’re particularly valuable for Medicare-Medicaid dual eligibles, suggests a new report from Elevance Health, Inc.’s Public Policy Institute. Following legislation and regulatory changes in 2018 and 2019 that established new types of supplemental benefits and expanded the definition of what CMS considers “primarily health-related,” payers began to offer supplemental benefits that target members’ health-related social needs (HRSNs), such as food insecurity and lack of access to transportation. Elevance is one of the first payers to release any data on the uptake and utilization of these benefits, while research on duals’ unique social needs and supplemental benefit use continues to emerge. A July 2023 study from Humana Inc., for example, found that 80% of duals in a sample population of its MA enrollees reported experiencing at least one HRSN, vs. 48% of non-duals. Deft Research in its 2023 Dual Eligible Retention Study, meanwhile, found that duals “absolutely depend” on their supplemental benefits and are likely to switch plans if not satisfied with their supplemental benefits.