Last week, Illinois became the fourth state to sign a Memorandum of Understanding with the Centers for Medicare & Medicaid Services (CMS) and take the next step in creating a dual eligible demonstration project aimed at integrating care for people eligible for both Medicare and Medicaid (“dual eligibles”). Originally projected to begin on January 1, 2013, this project is now set to launch on October 1, 2013. Other states, including Washington and Massachusetts, have in recent months also announced they will delay the startup of their demonstration projects.

The slowdown is welcome news for beneficiaries and the advocacy community, who thought the demonstrations were moving too fast without proper attention to an array of important design issues. These issues include the use of passive enrollment, where the beneficiary is automatically enrolled into a state-selected health plan unless s/he chooses a different plan or opts out of the program altogether. They also include concerns about whether the states and health plans have adequate infrastructure and networks in place to take on such a major transition.

Community Catalyst recently released policy briefs to help consumer advocates and other stakeholders sort through these two issues:

  • The Dual Eligible Demonstration Projects: The Passive Enrollment Challenge explains concerns for affected beneficiaries and recommends alternatives to passive enrollment and policy options that might ease beneficiary concerns. Among those recommendations is that all states use a voluntary enrollment period before launching passive enrollment, an approach which Illinois plans to use.
  • The Dual Eligible Demonstration Projects: State and Health Plan Readiness summarizes concerns around state and health plan capacity and offers recommendations for evaluating readiness based on what matters most to dual eligible beneficiaries. While Illinois has already selected health plans, it has not yet released the tool it will use to evaluate their readiness to serve dual eligible beneficiaries, especially those with the most complex health care needs.

While the delayed startup and use of a voluntary enrollment period are positive, the work does not stop here. The timetable for implementation is still aggressive and many elements of the project still need to be fleshed out before beneficiaries can be enrolled. It will be important for advocates to continue to push CMS, states and health plans to ensure consumer protections are in place before implementation.

Stay tuned for more analysis of the Illinois MOU.

— Leena Sharma, State Advocacy Manager, Integrated Care Advocacy Project