March 7, 2022
DREDF, in collaboration with the Community Living Policy Center at the Lurie Institute for Disability Policy at Brandeis University submitted comments to the Centers for Medicare & Medicaid Services (CMS) on proposed changes to regulation of Dual-Eligible Special Needs Plans (D-SNPs) as part of a larger rulemaking on Medicare Part C & D. We support the direction of CMS’s proposals and appreciate the efforts to tighten and clarify requirements and the focus on enrollee experience and needs. Our comments primarily explore areas where we believe that CMS could include further specificity in the regulations such as advisory committees, network adequacy, durable medical equipment, and home health care. These regulations are important given the rapid growth of D-SNPs across the country.