Two Ways CMS Can Meaningfully Improve Medicare Plan Finder for People Who Are Dual Eligible

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AUTHOR – Sarah Rosenblum

Choosing a Medicare plan can be overwhelming, but for people who are eligible for both Medicare and Medicaid (referred to as individuals who are “dual eligible”), it is even more complicated as they must decide how to receive benefits from both programs.

As we approach open enrollment for the 2024 plan year, individuals who are dual eligible are faced with choosing between an average of 35 different Medicare Advantage plans per county (Figure 1).[1]

Figure 1: People Who are Dual Eligible Must Navigate a Large Number of Plan Options, 35 on Average: Plans by County, 2023

The Centers for Medicare and Medicaid Services’ (CMS) online Medicare Plan Finder is the primary electronic tool available to help people understand what coverage options are available to them. However, this tool is particularly challenging to navigate if you are dual eligible.

Dual eligible special needs plans (D-SNPs) are a specific type of Medicare Advantage plan designed to coordinate people’s Medicare coverage with their Medicaid coverage when they are eligible for both programs. This type of coordination can greatly improve people’s experience navigating these two complicated programs. Yet, Medicare Plan Finder does not currently prioritize this plan option for individuals who are dual eligible, nor does it accurately portray all their available benefits. As a result, dual eligible individuals using Medicare Plan Finder can be misled about what plan best meets their needs. CMS has an opportunity to update this tool to improve its utility and reduce confusion for this population that heavily relies on their insurance coverage.

Why Plan Choice is Particularly Important – and Challenging – for Individuals Who Are Dual Eligible

Compared to individuals who are only enrolled in Medicare, people who are dual eligible are more likely to have more than three chronic conditions, take more medications, and have higher rates of functional and cognitive need. In addition to their higher clinical needs, people who are dual eligible also have higher rates of social risk factors than people who only have Medicare. Dual eligible individuals are more likely to be low income, be unmarried, experience food insecurity, have limited English proficiency, and have less than a high school education.[2] These realities mean that making a well-informed coverage choice is particularly important for this population.

But it is also particularly complex.

Similar to people who only have Medicare, people who are dual eligible need to consider health plan provider networks and benefits as part of their plan selection process. Unlike Medicare-only individuals, however, dual eligible individuals need to consider provider networks and benefits across multiple programs and plans that may not work together. These provider networks and benefits are often detailed across multiple websites. For example, Medicaid may cover benefits that are not listed as covered on Medicare Plan Finder because they are not covered by the Medicare program; or vice versa, Medicare Plan Finder might show plans covering certain benefits via Medicare even though those benefits are already be covered by Medicaid. This makes it difficult for people who are dual eligible to accurately compare benefits across plans and understand what they are enrolling in.

How Medicare Plan Finder Works Today

Medicare Plan Finder is the primary search tool for exploring Medicare plan options for beneficiaries, their caregivers, and State Health Insurance Assistance Program (SHIP) counselors.[3] An individual answers a series of questions about their specific circumstances (e.g., “Do you get help with your costs from one of these programs?” Medicaid, Supplemental Security Income, Medicare Savings Program, etc.) and the type of coverage they are seeking, and based on their responses, Medicare Plan Finder provides a list of Medicare plan options.

For individuals seeking coverage through Medicare Advantage, Medicare Plan Finder includes filters for plan type, plan benefits and coverage, and Star Rating. The tool also allows a person to view Special Needs Plans like D-SNPs in addition to general Medicare Advantage plans. Notably, however, a person cannot filter to view only D-SNPs. Medicare Plan Finder defaults to listing plans in rank order based on lowest drug and premium cost. An individual can also choose to sort plans by lowest deductible or lowest premium.

Recommendation #1: For Individuals Who Indicate They Have Medicaid Coverage, Medicare Plan Finder Should Display D-SNPs First

Medicare Plan Finder’s sorting approaches, including the default of lowest drug and premium cost, are not meaningful to people who are dual eligible. This population has Medicaid coverage that typically covers Medicare costs, including Medicare Part B premiums and drug costs. However, because of the information Medicare Plan Finder catalogues and prioritizes – and its lack of consideration for Medicaid coverage – D-SNPs may appear to be more costly than a standard Medicare Advantage product, resulting in D-SNPs displaying farther down in the plan results pages due to the tool’s default sort. Dual eligible individuals and people helping them with enrollment decisions are often faced with more than a dozen non-D-SNP plan options before seeing the first available D-SNP in their county. For example, a dual eligible individual in Taos, NM must scroll through 15 plan options across two webpages before seeing the first D-SNP out of 35 plans (Figure 2).

Figure 2: Screenshot of Medicare Plan Finder with the “Plans for people who have Medicare and Medicaid” Filter On, with a non-D-SNP Option Listed First

In addition, when Medicare Plan Finder lists a D-SNP option, there is no clear indication that the term “D-SNP” – often buried in the plan name – or the small font under the monthly premium saying “This plan is designed for beneficiaries with Medicare and Medicaid,” indicates a meaningfully different option from other Medicare Advantage plans in the county (Figure 3). And within the D-SNPs listed on Medicare Plan Finder, there is no additional detail on a D-SNP’s level of integration, like whether the D-SNP is fully integrated with a holistic benefit package of Medicare and Medicaid services, or a D-SNP that only coordinates Medicaid services but does not provide them.

Figure 3: Screenshot of a D-SNP on Medicare Plan Finder with the “This plan is designed for beneficiaries with Medicare and Medicaid” Descriptor*

*Note that the box in the screenshot above has been added for emphasis and is not displayed on the live Medicare Plan Finder site.

CMS should update Medicare Plan Finder to default to listing D-SNPs first for people who are dual eligible, and within the category of D-SNPs, plans should be ordered by level of integration: Fully Integrated Dual Eligible (FIDE), Highly Integrated Dual Eligible (HIDE), then Coordination Only (CO) D-SNP. Medicare Plan Finder can also visually highlight these plans, for example adding an obvious statement immediately after the plan name that acknowledges the plan is designed specifically for people with both Medicare and Medicaid coverage. Ideally, the explanatory text for D-SNPs would include more information about how D-SNPs better coordinate Medicare and Medicaid benefits. CMS could also consider adding a question to the Medicare Plan Finder tool that asks people who are dual eligible whether they have a Medicaid managed care plan and, if so, which organization that plan is with. For dual eligible people who answer this question, CMS could indicate and prioritize D-SNP(s) offered by the same parent organization on the plan results page.

Recommendation #2: Medicare Plan Finder Should Provide a More Complete Picture of the Benefits Available to People Who are Dual Eligible

Through a series of eye-catching green checkmarks and red “x” marks, Medicare Plan Finder indicates whether Medicare Advantage plans provide coverage for select supplemental benefits offered through Medicare (Figure 4). Consumer advocates and SHIP counselors anecdotally report that these benefit lists often influence enrollment decisions, with potential enrollees seeking out plans with more green and less red.

However, Medicare Plan Finder’s current display of supplemental benefits can be confusing to dual eligible individuals and the people helping them make enrollment decisions because in addition to Medicare benefits, people who are fully dual eligible receive Medicaid benefits. A red “x” on Medicare Plan Finder can be misleading when a dual eligible individual receives that benefit through Medicaid, and it can make a D-SNP appear to offer fewer benefits than a non-D-SNP Medicare Advantage plan. In reality, a D-SNP may not provide Medicare supplemental benefits already covered by and redundant to Medicaid but rather, offer a more robust, holistic benefit package that includes higher-value benefits not displayed on Medicare Plan Finder.

A consequence of the tool’s current display is people who are dual eligible making ill-informed enrollment decisions. Duals eligible people who unintentionally enroll in a non-D-SNP Medicare Advantage plan may be confused to find that their new Medicare plan does not coordinate any benefits or coverage with Medicaid.

Figure 4: Screenshot of Plan Comparison on Medicare Plan Finder, with Fewer Benefits Listed Under the D-SNP

CMS should facilitate a clearer comparison of benefits for people who are dual eligible across all Medicare Advantage plans, including D-SNPs. This would require incorporating Medicaid coverage information into D-SNPs’ list of benefits. For example, CMS could update the D-SNP list of benefits to include green checkmarks or an alternative to a red “x” next to benefits covered by Medicaid. To do so, CMS could require D-SNPs to submit Medicaid benefit information as part of their Medicare Plan Benefit Package (PBP) files, which are already submitted to CMS. CMS also could extract this information from D-SNP State Medicaid Agency Contracts (SMACs) in states that include Medicaid benefits in the contract.  

Moving Forward

Choosing a Medicare plan is complicated, especially for dual eligible people who have to consider the role of Medicaid alongside their Medicare enrollment decision. Medicare Plan Finder is an important tool to help people who are dual eligible, and the individuals who help them, make critical enrollment decisions and choose the plan that best meets their needs. However, the current Medicare Plan Finder design is not meeting the unique needs of this population.

While there is important nuance in plan selection that an online tool alone cannot provide, there are opportunities to improve Medicare Plan Finder to help people who are dual eligible make more informed choices and to prevent inappropriate plan choice that stems from confusing or misleading information. The two solutions outlined above are example steps CMS can take now for future plan years to meaningfully improve Medicare Plan Finder for people who are dual eligible, their caregivers, and SHIP counselors.

Special thanks to Community Catalyst, Medicare Rights Center, the Association of Community Affiliated Plans, Justice in Aging, Special Needs Plan Alliance, and Kenton Johnston of the University of Washington St. Louis Medicare Innovation Research Lab for their input on the problems and solutions discussed in this blog.

[1] ATI Advisory analysis of 2023Q2 PBP data. Excludes CSNPs, I/IESNPs, PACE, FAI MMPs, HCPPs, MSAs, and Employer Group plans.

[2] ATI Advisory (2022). “A profile of Medicare-Medicaid Dual Beneficiaries

[3] SHIP counselors are state-based, unbiased Medicare counselors who help beneficiaries navigate their plan decisions free of charge.

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