DHCS Accepting Public Comment on CalAIM D-SNP Proposal

The Department of Health Care Services (DHCS) released “Expanding Access to Integrated Care for Dual Eligible Californians” for public comment. This memo outlines the department’s transition plan within the California Advancing and Innovating Medi-Cal (CalAIM) to improve the quality of life and health outcomes of our population by implementing broad delivery system, program and payment reform across the Medi-Cal program.

Please submit feedback on this proposal to CalAIM@dhcs.ca.gov with the subject line: Expanding Access to Integrated Care for Dual Eligible Californians. Public comments are due by 5 p.m. PST on Friday January 31, 2020.


In order to achieve a more standardized approach to comprehensive care coordination for all populations, DHCS is proposing to discontinue the Cal MediConnect pilot program at the end of calendar year 2022. DHCS proposes to transition from the pilot approach of the Coordinated Care Initiative to standardized mandatory enrollment of dual eligibles into a Medi-Cal managed care plan for Medi-Cal benefits and integration of long-term care into managed care for all Medi-Cal populations statewide.

For more information on this proposal, visit the California Advancing and Innovating Medi-Cal (CalAIM) . For any other comments, questions, or concerns, please contact CalAIM@dhcs.ca.gov

  1. Susan LaPadula

    Thank you for this opportunity to comment on DHCS’s transition plan within the Medi-Cal Healthier California for All initiative (formerly known as CalAIM). 
    Electronic coordination of crossover claims for dual eligible members,  Medicare Part A and Part B CoInsurance and Deductible  payments for all California contracted health plans is a priority for government entities, providers, health plans and most importantly beneficaries. 

    1) This concept will align with our Governor’s Initiative:  A MASTER PLAN FOR AGING Executive Order Issued and signed  by Governor Newsome on June 10, 2019.
    Statistics from the Executive Order include:
    🔷California’s Population To Grow To 8.6 Million by 2030🔷An Increase of 4 Million (age 65 +) Older Californian’s over the next decade. (Annual Average = + 400,000 additional Medicare Age (Older Californian’s requiring healthcare) in our State. A Master Plan for Aging is a Blueprint For State Government,  Local Government & Private Sector.

    2) Department of Health and Human Services FINAL RULE published in 45 CFR 162
    Electronic Coordination of Benefits Agreement (COBA) Crossover Claims for dual eligible members(Medi-Medi =FFS)
    Several of the County Organized Health Systems (COHS) have accomplished Electronic Coordination of Benefits and are operational today.
    Examples:  a) Ventura County COHS : Gold Coast Health Plan 
                      b) Orange County COHS:    Cal Optima Direct                           

    The CMS Coordination of Benefits Agreement (COBA) is the vehicle for accomplishing automation. As an industry, we are grateful this mechanism is in place, working well and monitored however we would like to request the automation of all California “duals” Medicare Part A & Part B CoInsurance for all California Medi-Medi (Medicare-Medi-Cal) beneficiaries.

    Let’s build on the infrastructure of an automated Coordination of Benefits (COB) for all California dual eligible beneficiaries statewide in the Medi-Cal Healthier California for All initiative (formerly known as CalAIM). CMS COBA will provide testing and full production status to all health plans for all lines of business.

    Currently All Seven (7) Counties of the Coordinated Care Initiative CCI (LA, Orange, Riverside, San Bernardino, San Diego, San Mateo & Santa Clara) serving Cal MediConnect Members and all Health Plans responsible for Medi-Cal portion and Medicare portion do not utilize an automated coordination of benefits, even if this within the same plan responsible for both the Medi-Cal & Medicare portions.

    2- All Health Plans conducting business in California offering  Medi-Cal Managed Care Fee-For-Service Benefits to beneficiaries who are also Medicare Beneficiaries LTSS & Medicare wrap around benefits (includes Medi-Cal Managed Care Plan Types: Two-Plan, Imperial, San Benito, Regional Model, GMC Geographic Managed Care, COHS County Organized Health System and Cal MediConnect) should be expected to use the CMS COBA Coordination of Benefits Agreement and attain production status, not just testing status.
    Please consider these additional points as we continue to work together towards our common goals in this collaboration. Let’s improve quality of care and reduce the unnecessary paperwork associated with our healthcare delivery system. Please automate the Coordination of Benefits (COB) for all California dual eligibile beneficiaries statewide in the Medi-Cal Healthier California for All initiative (formerly known as CalAIM). 

    Thank you for your consideration.

    With Respect and Gratitude,
    Susan LaPadula

    • Admin

      Hello Susan – thank you for your comment. We have forwarded your feedback to the Medi-Cal Healthier California for All inbox, CalAIM@dhcs.ca.gov.

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