Understanding 2025 Medicare Advantage and Part D Enrolment Guidance Updates

Relevant to: Enrollment and Payment Systems, PACE, Part D

Each week, we scan the latest CMS memos to find the most important ones that apply for PACE programs. Below is a summary of what you need to know.

Disclaimer: The content provided on this site is a summary for informational purposes only, and Grane PBM, Inc. assumes no liability for any errors or omissions in the site’s content. The information does not constitute legal or regulatory advice or replace the original CMS memo. Readers are advised to consult the CMS memo in its entirety and to verify information independently before making any decisions based on this information.

Click here to read the complete memo from CMS.

Introduction

The CMS has issued comprehensive guidance for the 2025 Medicare Advantage and Part D programs, focusing on alignment and simplification for dual eligible individuals. Changes under § 422.514(h) will impact enrollment in Dual Eligible Special Needs Plans (D-SNPs) beginning in 2027, requiring them to affiliate with Medicaid managed care organizations (MCOs) in their service areas. This aligns with the broader policy shift aimed at enhancing coordination between Medicare and Medicaid services.

Key Dates and Deadlines

  • Date: January 8, 2025 – Memo Released by Centers for Medicare & Medicaid Services
  • August 8, 2024 – Parts C and D Enrollment and Disenrollment Guidance Released
  • Beginning in 2027 – Enrollment restrictions in certain D-SNPs come into effect

PACE Compliance

The memo and related resources have implications for Programs of All-Inclusive Care for the Elderly (PACE) due to the changes in the Medicare Advantage and Part D. Compliant entities should carefully examine the updates to ensure their plans align with the new provisions highlighted in the final rule and guidance documents.

The Medicare Advantage final rule Section 422.514(h) introduces significant changes that focus on limiting enrollment in certain Dual Eligible Special Needs Plans (D-SNPs) and aligning these plans with Medicaid managed care organizations (MCOs). This alignment is essential for maintaining compliance with the revised requirements that will affect plan offerings both for MA organizations and affiliated Medicaid MCOs starting from 2027.

To comply:

– Assess the current plan structures against the new requirements for integration and affiliation as outlined.
– Confirm that all D-SNPs, regardless of their integration status, adhere to the revised Section 422.514(h) if they contract with a state as a Medicaid MCO.
– Regularly review updates to guidance documents such as the Medicare Advantage and Part D Enrollment and Disenrollment Guidance to ensure ongoing compliance.

Non-compliance with these revised provisions could impact plan approvals and service delivery in affected areas, emphasizing the need for a strategic review and adjustment of current practices.

Required Actions

This memorandum provides important clarifications and corrections concerning the enrollment and disenrollment guidance for Medicare Advantage and Part D plans, specifically relating to Dual Eligible Special Needs Plans (D-SNPs). Below is the list of actions to be taken:

1. Review the attached FAQs on the CMS website to ensure understanding of the provisions at § 422.514(h) and their impact on your offerings.

2. Update your organization’s processes and communications to reflect the corrected enrollment and disenrollment guidance, noting that all D-SNPs are potentially subject to § 422.514(h).

3. Monitor the CMS website for future updates to the guidance to ensure ongoing compliance with Medicare policy changes. Make adjustments as necessary to align with the correct guidelines provided by CMS.

FAQs

“What is § 422.514(h) and how does it affect D-SNP enrollment?”
“How are the 2025 regulations different from previous Medicare Advantage rules?”
“Who is impacted by the changes to D-SNP benefit packages?”
“How does the correction to the 2025 Enrollment and Disenrollment Guidance impact current D-SNPs?”
“What are the integration levels required for D-SNPs under the new rule?”

Click here to read the complete memo from CMS.

Contact Us

Let's Discuss How We Can Support Your Business

Get real-time memo alerts in your inbox