We are asking that you take a look at this policy again. While this is not new policy, CMS determined it was pertinent to recommunicate this policy and its implications; this, more than likely, signals that there will be closer scrutiny and lower tolerance for marketing activity and growth strategy that appears to target low-income individuals, unless it is for a DSNP plan. As a review:
- MAPD and PDP plans that are not DSNPs cannot be designed, positioned, or grown in a way that drives dual-eligible enrollment (think of the look-alike plans)
- Plan sponsors are responsible for the behavior of agents, brokers, and marketing organizations. Incentives and market prioritization are in scope for CMS review under this policy
- Plan growth among dual-eligible populations is acceptable through DSNPs only. This signals that CMS will be looking at numbers of low-income individuals enrolled in non-DSNP plans and if there are substantiative increases, the agency will want to see how that was attained