D-SNP Proposal and LTC Carve-In FAQ Discussed at LTSS Collaborative Webinar

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 moving forward the automation of Medicare
Part A & Part B CoInsurance for all California Medi-Medi beneficiaries.

Let’s build the infrastructure of an aligned, automated
Coordination of Benefits (COB) for all California
dual eligibles beneficiaries statewide in
the Medi-Cal Healthier California for All initiative (formerly known as CalAIM).

1- All Seven (7) Counties of 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.

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).

Please consider these additional points as we continue to work together towards our common goals and work towards alignment.

To 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 eligible beneficiaries statewide in
the Medi-Cal Healthier California for All initiative (formerly known as CalAIM).
Thank you kindly.

With Respect and Gratitude,
Susan LaPadula