Response to 60-Day Comments

Summary of Comments and Responses for 60-day PRA Integrated Annual Notice of
Change (ANOC) and Evidence of Coverage (EOC) Models
General Comments
Comment

Response

Gathering input about how to increase the
linguistic and cultural relevance of the ANOC
should begin with beneficiaries. To understand
how consumers experience the ANOC, CMS
should solicit feedback from diverse voices
reflective of the demographic diversity of people
dually eligible for Medicare and Medicaid. For
example, listening sessions should be conducted
in languages beyond English and Spanish.
Including consumers in the ANOC development
process can help CMS to deliver information in a
more meaningful manner to people dually
eligible for Medicare and Medicaid.
The ANOC is an important document, as it
informs plan members of key changes that may
influence their decision to continue membership
in the plan. To that end, the ANOC should be
person-centered, provide information with
specificity, and deliver information in a userfriendly manner. To achieve its purpose,
highlighting the upcoming changes to the plan at
the beginning of the document quickly alerts
enrollees of changes that may directly impact
them. In its current form, information about plan
changes does not appear until page 8 of the
document. To make it easier for enrollees to
comprehend upcoming changes, we suggest
adding a summary with highlights or bullet
points on the first or second page of the ANOC.
For example, the summary section could flag
that the plan name or prescription drug copayments are changing and then reference the
page number and accompanying section where
the change is discussed in more detail. Given
that changes could influence a consumer’s
decision to remain in the plan, information about
how to change plans can also be raised earlier in
the document than in its current location on page
16. We also suggest that the document be

CMS appreciates the comment and agrees
that consumer input is important. These
model materials (henceforth models) were
created based on models that were used for
the Financial Alignment Initiative, which
were informed by consumer input and
testing. CMS will consider additional
consumer input for future cycles.

CMS appreciates the comment and agrees
that the ANOC is an important document.
However, CMS did not make any changes
to the document because the model includes
several pages of instructions to plans that
will not be included in the actual document
that enrollees receive. There is also a
summary of changes in the introduction for
the enrollees, and the detailed information
on the changes are included a few pages
into the document.

Comment
personalized to the beneficiary. For example, on
page 3, instead of giving Dual Eligible Special
Needs Plans (D-SNPs) the option to address the
document to the member by name, CMS should
make using the individual’s name a requirement.
The ANOC and EOC should use plain language
when possible. Plans must explain acronyms and
less common terms in consumer-friendly
language and provide relevant examples. Longterm services and supports are referenced
multiple times in the EOC chapters; although
this is a common term used by health care
providers and health plans, the meaning may be
obscure to the average consumer. Examples are
helpful to illustrate services offered under longterm services and supports or an explanation of
how care coordination would benefit a
consumer. CMS should also consider developing
standardized language to describe care
coordination and care coordinators. While plans
should continue to have the discretion to
describe care coordination to some extent,
developing standardized language or simple
requirements, such as using examples, will
ensure that all plans provide a basic description
of care coordination that is meaningful.
Current regulations permit hard copies of the
ANOC and EOC to be mailed or delivered
electronically. Plans should be required to mail
these documents by default unless the consumer
affirmatively elects to receive these
communications by electronic mail. Dually
eligible individuals may not have ready access to
technology, may not frequently check email
communications, or may need assistance using
technological devices. As a default, these
materials should be delivered by mail while
allowing consumers to elect electronic delivery.
As previously indicated, people dually eligible
for Medicare and Medicaid are more diverse
than Medicare-only recipients. Therefore,
analysis of the ANOC must consider how to
improve the document’s accessibility for
subpopulations, including LEP enrollees.
Information about alternative languages and

Response

CMS understands the need for simple
language and to provide examples of terms.
Over time, CMS has worked to increase the
use of plain language in models, including
spelling out acronyms the first time they are
used. CMS will continue to review ways it
can develop more standardized language for
terms such as care coordination for future
cycles.

CMS has moved language regarding how to
receive materials in alternate languages and
formats to earlier in the introduction as well
as included information on interpreter
services. The current requirements for
mailing materials are included in regulation
at 42 CFR 422.2267(d), which include the
ability to mail a notice informing enrollees
how to access materials but also include the
option for enrollees to request a copy of
materials in writing.
In addition, since these materials cover both
Medicare and Medicaid services, the
requirements for both programs apply to the
materials.
Finally, the CY 2024 Medicare
Advantage/Part D proposed rule, if

Comment

Response

formats is not found in the ANOC until page 6,
section B1. To increase the prominence of
information about translated materials and
alternative formats in the ANOC, we suggest
that CMS provide this information as an insert or
cover sheet. Consumers that receive the ANOC
in English, but need translated materials or
alternative formats, may not read to page 6 of the
document to learn they can receive these
materials in the language or format they need.
An insert or cover sheet quickly alerts the
consumer that translated and alternative format
materials are available and provides critical
information on how to request these materials. In
addition to providing this information earlier in
the document or as an insert, we encourage CMS
to explore options to relay information about the
plan’s language and accessibility features in as
many languages and formats as possible. For
example, CMS should consider including an
insert containing information about language
assistance services and alternative document
formats in the threshold languages in the plan’s
geographic area. In all respects, D-SNPs and
Medicaid plans serving the same geographic area
should be subject to the same language
accessibility requirements, and should be
whichever is most favorable to the beneficiary. It
would be confusing for an enrollee to receive the
ANOC and EOC in English and materials from
their Medicaid plan in their preferred language.
Additionally, information about language
assistance services could be included at the
bottom of every page of the document to
improve access. The ANOC currently contains
optional language for plans. This content, for
example, on page 2, provides plans with the
option of using “regionally appropriate terms or
common dialects in translated models.”
Regionally appropriate language is more likely
to resonate with specific communities,
improving the document’s usability for
particular subpopulations. When regionally
appropriate terminology is available, this content
should be included in the document and, to

finalized, would require plans to provide
materials to enrollees in alternate languages
and/or formats as a standing request upon
learning of the enrollee’s preference. The
proposed rule would also clarify that fully
integrated dual eligible (FIDE) special
needs plans (SNPs), highly integrated dual
eligible (HIDE) SNPs, and applicable
integrated plans (AIPs) must translate
required materials, including the ANOC and
EOC, into any languages required by the
Medicare translation standard plus any
additional languages required by their
state’s Medicaid translation standard.

Comment

Response

ensure relevance, be subject to beneficiary
testing. As another example, plans currently
have the option of providing translated materials
in large print. Accessibility features should be
available to all enrollees, regardless of the
language of the materials they receive.
Therefore, plans should be required to provide
translated materials in large font, upon request,
to consumers. We do not imagine that the
requests for large print materials would be so
great that they would cause a significant
financial burden to health plans.
We encourage CMS to explore options beyond
text to relay information in the ANOC. To
demonstrate this need, consider the consumers
that do not recognize their enrollment in
Medicare until they are shown a picture of a
Medicare card. Simple visuals, such as a pill to
denote medicine or an apple to signify
preventative care, as found in The Medicare &
You handbook, help orient readers to the subject
matter outlined in the accompanying text.
Additional formatting choices in the handbook,
such as charts, text boxes, and arrows containing
the word “Important,” direct the reader to pay
close attention to specific content while breaking
up the dense text to make the document more
visually accessible. While formatting
suggestions gathered from consumers, such as
plain language and bulleted lists, have been
incorporated into the document, additional
efforts could be taken to advance the document’s
accessibility. We encourage CMS to explore
opportunities to use images and formatting
alternatives to make the ANOC more userfriendly. Beneficiary outreach is yet another
method to enhance members’ understanding of
their benefits. CMS might consider directing
plans to discuss beneficiary-specific changes
outlined in the ANOC with members as part of
their ongoing case management duties. For
example, the ANOC currently instructs members
to contact Member Services to discuss changes
related to their medication coverage. Instead of

CMS appreciates the feedback. These
models were created based on models that
were used for the Financial Alignment
Initiative, which were informed by
consumer input and testing. CMS will
consider additional consumer input, as well
as continue to review ways it can deliver
information in a more meaningful manner,
for future cycles.

Comment
placing the sole responsibility of outreach on the
beneficiary, we alternatively suggest that plans
contact enrollees to discuss plan changes, answer
questions, ensure access to accessibility features,
and assist with benefits navigation. We believe
that this additional support from plans will
enhance members’ understanding of their
benefits, improve access to critical resources like
medications, and ultimately improve their health
outcomes. Precedence for this type of outreach
already exists in California. Health plans
participating in California’s Financial Alignment
Initiative (FAI) are conducting telephone calls to
their members to alert them of the transition into
exclusively aligned D-SNPs. Telephone calls are
person centered, ensure enrollees are aware of
critical changes, and offer an opportunity for
enrollees to ask questions about their plan.
Our analysis identified a few areas of the ANOC
that likely fuel confusion. For example, costsharing references throughout the document may
confuse Qualified Medicare Beneficiaries
(QMBs) or those full-benefit dual eligible who
do not have costs associated with their benefits.
At the same time, removing cost-sharing
references altogether may result in a need for
more awareness amongst consumers of the
savings related to their dual eligibility status. As
this example demonstrates, beneficiary testing is
needed to better understand how consumers
interpret this information to improve messaging.
As another example, when the document
encourages readers to reference a section of the
ANOC or EOC, a brief explanation should
accompany the section name to help the reader
understand its content. We urge CMS to utilize
language beyond “Refer to Section E,” as found
on page 5, and instead use language like “Refer
to Section E for information about changes to
our drug coverage,” as seen on page 7. This
additional information helps to orient the reader
to the section’s content and makes the document
easier to navigate.

Response

CMS appreciates the comments about how
and whether to describe cost-sharing. For
example, it is possible for an AIP D-SNP to
have Medicaid copays for Medicare Parts A
and B as well as LIS cost-sharing for Part
D. Therefore, CMS has included all costsharing language in the model as variable so
it can be customized to the rules in a
particular state and program. The language
that the enrollee receives from the plan
should be more specific to their coverage
since plans are required to include the actual
cost-sharing for the enrollee which can vary
by state. CMS also appreciates the
comments on references but did not make
any changes at this point because the
references are sufficiently clear. CMS will
consider additional consumer input, as well
as continue to review ways CMS can
deliver information in a more meaningful
manner, for future cycles.

Comment

Response

We would like to confirm if the option to use
new EOC and ANOC models only applies to
exclusively aligned HIDE SNPs and exclusively
aligned FIDE SNPs or does it apply to other
types of D-SNPs as well? When must the states
declare that they opt to use the new models
instead of the standard D-SNPs EOC/ANOC
models? What is CMS's timeline in
communicating to MA organizations the states
that require the use of these integrated models
and in releasing the final models for use?
Change the word Ombudsman to Ombudsperson

These models are for use only by D-SNPs
designated by CMS as AIPs in states that
require them. CMS is reaching out to those
states directly and the state will inform DSNPs if they plan to require the use of these
models. CMS and the states will work to
finalize models and the states provide them
to plans as soon as possible.

CMS accepts this edit and will change the
language throughout the document.
CMS appreciates the comment. These
models were created based on models that
were used for the Financial Alignment
Initiative, which were informed by
consumer input and testing. CMS will
consider additional consumer input, as well
as continue to review ways it can deliver
information in a more meaningful manner,
for future cycles.

We urge extensive use of consumer testing to
ensure the ANOC and EOC achieve the right
balance of information and approachability. Too
much information is overwhelming, too little is
useless. Generally speaking, we found the drafts
had a good balance, but we are also aware that
many readers may be approaching the material
without previous knowledge of or understanding
of how Medicare Advantage works and what
their rights and responsibilities are. We
encourage testing around language, organization,
and what information in the ANOC is necessary
and what may be left to the EOC.
We also urge personalization to the extent
CMS appreciates the comment. The variable
possible to ensure that people get information
fields will allow state-specific
best tailored to their circumstances.
customization of Medicaid information in
the models. CMS will consider additional
consumer input, as well as continue to
review ways it can deliver information in a
more meaningful manner, for future cycles.
A trade association supports the proposed
CMS appreciates the comments and
changes to the ANOC and EOC for D-SNPs that support.
are applicable integrated plans (AIPs). CMS
properly notes there are advantages to receiving
communications that integrate all the required
Medicare and Medicaid content, including
providing a more seamless description of health
care coverage and enhancing the understanding
of, and satisfaction with, the coverage both
programs provide. The SNP Alliance has long
advocated the integration of member materials as
important for improving beneficiary experience

Comment
and outcomes. We appreciate the actions taken
here to advance integration.
We request that final models be provided
no later than early May, and final approvals from
the State by 8/1, to allow sufficient time for
development, quality review, translations, and
print production to meet the 9/30 (ANOC
mailing) and 10/15 (online posting) deliverables.
Global comment for proposed integrated ANOC
and EOC models: The content layout does not
align with the current D-SNP model.
UnitedHealthcare (UHC) recommends
remaining consistent with the current models as
creating a whole new format and content creates
risk in developing the documents and increases
time required to manage additional models.

Response

CMS appreciates the comment and will
work to provide models as soon as possible.

CMS appreciates the comment. These
models were created based on models that
were used for the Financial Alignment
Initiative, which were informed by
consumer input. These models, similar to
the Financial Alignment Initiative models,
are formatted to provide all Medicare and
Medicaid information to enrollees in one
document to make it easier for these
enrollees to understand the benefits that are
available to them across both programs.
CMS will consider additional consumer
input, as well as continue to review ways it
can deliver information in a more
meaningful manner, for future cycles.

ANOC Comments
Comment

Response

The new ANOC in particular is a marked
improvement over past versions, with more
streamlined text and more visual appeal, including
better use of white space and readable fonts.

CMS appreciates the comment and
support.

Though it would extend the length of the document, CMS will consider additional consumer
we encourage the use of tested graphics to guide
input, as well as continue to review
readers and flag important details.
ways it can deliver information in a
more meaningful manner, for future
cycles.
We urge clarifying what language help is available CMS appreciates the comment, and has
early on to ensure people see it immediately. The
moved this language to an earlier
reference in the ANOC is not until B1. For
location in the document.
comparison, in the Medicare & You Handbook, the
information is on page two in the introduction.
Plans currently have the option of providing
CMS has deleted the ambiguous
translated materials in large print. Accessibility
language in the ANOC and EOC related
features should be available to all enrollees,
to accessibility. All MA organizations
regardless of the language of the materials they
and Part D sponsors must comply with
receive.
section 504 of the Rehabilitation Act of
1973, section 1557 of the Affordable
Care Act, and implementing regulations
at 45 CFR part 92. The regulations at 45
CFR 92.102(b) require plans to provide
appropriate auxiliary aids and services,
including interpreters and information in
alternate formats, to individuals with
impaired sensory, manual, or speaking
skills, where necessary to afford such
persons an equal opportunity to benefit
from the service in question.
We suggest the use of cover sheets or early pages
CMS appreciates the suggestion. CMS
that list major or confusing changes with references will consider additional consumer input,
pointing the reader to more information. The
as well as continue to review ways it can
Medicare & You introduction (page two) could
deliver information in a more
serve as a guide.
meaningful manner, for future cycles.
CMS agrees that the Medicare & You
Handbook is a good example for
consideration.

Comment

Response

We suggest that some material may benefit from
being introduced sooner in the ANOC:
• Information about help in other languages
• Information about plan changes, including plan
name
• Information about what happens if the enrollee
does not choose another plan

CMS appreciates the suggestions and
has moved the multi-language insert
information to an earlier location in the
document. The information about plan
changes and what happens if the
enrollee does not choose another plan is
included within the first few pages of
the actual document that the enrollee
will receive. The current model includes
several pages of instructions, which will
not display in the version the enrollee
receives. CMS will consider additional
input, as well as continue to review
ways it can deliver information in a
more meaningful manner, for future
cycles.
CMS appreciates the comment, and has
added the word "Medicaid" in
parentheses to the header for section B.
Plans should use the state-specific name
for Medicaid throughout the document.
CMS has not included this information
because all enrollees that qualify for
AIP D-SNPs (which are the only plans
using these models) are deemed eligible
for the low-income subsidy (LIS).

We encourage the use of state-specific names for
Medicaid and also the use of “Medicaid” to ensure
enrollees understand both.
The ANOC does not include any information about
Extra Help and similar low-income assistance
programs, or identification of where to go to find
information about such programs. We recommend
adding this information to the introduction page,
and throughout as appropriate.
The ANOC uses “copay” instead of “cost-sharing.”
This may be confusing if plans employ and refer to
coinsurance. References to all forms of cost-sharing
should be clearly defined and used carefully,
considering that Qualified Medicare Beneficiaries
(QMBs) or some full-benefit dually eligible
individuals may not have costs associated with their
benefits and may be confused or dissuaded from
seeking care if they believe they will incur costs.

CMS appreciates this comment and uses
the term cost-sharing to encompass
copays, co-insurance, and deductibles.
Enrollees in AIP D-SNPs only includes
enrollees who are full- benefit dually
eligible (QMB+, SLMB+, other full
benefit dual eligible). For all Medicare
Part A and B services, cost-sharing is
either $0 or the Medicaid copay
applicable to that service (if the state
charges such copays and the affiliated
Medicaid plan does not waive such
copays). For Part D, the copay is one of
the Low-Income Subsidy (LIS) level
copays for full LIS until catastrophic
coverage, where there is no costsharing.

Comment

Response
The language is variable since the costsharing can vary from state to state.
Those states where there is no costsharing have the flexibility to modify
any language related to cost-sharing or
copays.

Instructions: We suggest adding direction to use
state-specific compliant language block per
guidance issued by the state.
Page 3, Introduction: Members receive this
document by September 30, but the Handbook and
other member materials are not posted on the
website until October 15. It would probably be
helpful to make note of that here so they aren’t
looking for the materials before they are available.
Page 4, Section B: This section appears to be
redundant to section G2. If decide to keep
recommend adding additional instructions. For
example, "Plans may insert state-specific Medicaid
enrollment options as applicable."
Page 5, Section B. Reviewing your Medicare and
[Insert name of Medicaid program] coverage for
next year. Regarding the sentence, "Refer to
Section E for more information," a health plan
commented: Does this mean more information
about benefits or more information about how to
leave the plan?
Page 5, Section B, 2nd paragraph, first sentence:
Plans should be able to edit this paragraph. This
paragraph is not accurate for one of our plans and
will need to be updated to reflect state guidelines
regarding disenrollment.
Page 7, Section B.3: "Are they in a different costsharing tier?" The plan recommends
removing the sentence.

CMS understands that some states have
specific language requirements. Section
A of the ANOC currently notes that
plans must include all disclaimers
included in state-specific guidance.
CMS appreciates the comment but will
maintain the current language. This is
standard language that is used in all
CMS models.
CMS rejects this suggestion as this is a
general introduction section which
refers the readers to enrollment options
in section G2.
CMS agrees for the need for
clarification. CMS has updated the
language to read, "Refer to Section E for
more information on changes to your
benefits for next year."
CMS has updated the language to allow
more flexibility for the Medicaid
coverage end date.
While CMS declines to remove this
sentence, it has modified the sentence to
include instructions to insert if
applicable and adjust the language as
needed.

Comment

Response

Page 7, Section B.3 regarding the language, "Check
if there are any changes to our benefits [insert if
applicable: and costs] that may affect you".
PrimeWest asks: If plans have no costs for medical
services but only for Part D drugs, should the
“costs” part be included here?

Since the ANOC includes medical and
drug benefits, if there are changes to the
cost of Part D drugs the language should
be included.

Page 12, Section E2-E3: The plan recommends
adding language from the D-SNP ANOC and EOC
models to describe the Defined Standard benefit
and cost-sharing if a member loses LIS.

CMS appreciates this edit but did not
add the suggested language from the DSNP ANOC and EOC models. The
language in the AIP D-SNP ANOC and
EOC models is tailored specifically for
dually eligible enrollees who have the
same plan for both Medicare and
Medicaid. These enrollees may find
language from the D-SNP ANOC and
EOC models to be confusing. All dually
eligible individuals are deemed or redeemed eligible for LIS for the next
plan year starting in July of the prior
year. That means an individual who has
lost Medicaid in the prior year and who
is not re-deemed LIS-eligible for the
coming plan year would have exhausted
any period of deemed SNP LIS
eligibility (maximum length is 180
days) by January 1 of the plan year.
Since LIS eligibility lasts for the full
plan year, even if the individual loses
Medicaid during the plan year, all DSNP enrollees will retain LIS eligibility
for the full plan year (JanuaryDecember).
Since this model is only for enrollees in
D-SNPs that are AIPs, they will all be
deemed for LIS and will not lose LIS
coverage during the year. As a result,
for the enrollee there are only two
payment stages they encounter (unless
the state pays the LIS cost-sharing
which means there is only one payment
stage.)
Yes, this would be considered a single
payment stage and the ANOC should
reflect this as appropriate.

Page 12, Section E.2: Changes to Prescription Drug
Coverage: The model only allows for single and
two payment stage charts. Will there be an option
to include a four-stage chart like the standard Part
D model? If not, where would we report changes to
coverage gap?

Page 12, Section E.2: For plans that file $0 RX on
all tiers through VBID, would this be considered
single stage?

Comment

Response

Page 12, Section E.2: Changes to Prescription Drug
Coverage. In the below chart in section E2 (page
12), for plans that file $0 RX on all tiers through
VBID, would that be considered single stage?

CMS has added language that indicates
only plans with multiple payment stages
should include this information in this
section. If there is $0 on all tiers, the
plan would not include this section.
CMS has modified the language to note
that plans should insert the TrOOP
amount.

Page 12, Section E.2 regarding the language
"[insert as applicable: $ or
$]". How should plans
determine which of these to use?
Page 13, Section E.3 Regarding the language:
"Refer to Chapter 6 of your Member Handbook for
more information about how much you pay for
prescription drugs." Is this sentence necessary? The
chart above tells them how much they pay. The
commenter also notes a word is missing in this
sentence - "...more information about..."
Page 16, Section G.2, page 16, first bullet, JanMarch - As we also note in Chapter 10, at present
we do not use these SEPs in any of our programs,
so this one would be the first, and it would require
reprogramming, testing, and extensive education
and outreach about this change.
Page 19, Section G.2 regarding the language
"[insert name of program, phone number, days and
hours of operation, and TTY number and website if
applicable]. Is this the name of the Medicaid
program?
Page 19, Section G.2, last paragraph: We anticipate
directing members to our enrollment broker’s call
center which plays this role today.
Page 20, Section H.2 regarding the language ".
[Insert name of program] HICAP " What is
HICAP? Should this say SHIP?
P 20, Section H2: Is the intent to have a Staff
Member’s Name?

CMS appreciates these comments. CMS
rejects this comment since it believes it
is helpful to let enrollees know where
they can find general information about
their prescription drug costs. CMS did
update the language in Section E.3 to
address the missing word.
CMS rejects this edit. This is a required
special enrollment period for dually
eligible individuals per 42 CFR
438.38(c)(4).
CMS has updated the language to note
that this is the name of the program as
directed by the state.
CMS has updated the language to note
that this is the name of the program as
directed by the state.
CMS has edited the document to delete
the word "HICAP" and instead changed
this to the SHIP.
CMS has deleted the word "staff." This
should just be the name of the program.

Comment

Response

Page 20, Section H.2, heading: Our first referral
after the plan would probably not be to the SHIP,
which seems to play a more limited role in our state
than others based on its prominence in these draft
models.
First, members should call our enrollment broker,
which operates a call center and is trained on these
topics. They are neither the SHIP nor the
ombudsman. Can we please have the flexibility to
include them before the SHIP?
Page 21, Section H.4 regarding the language "call
1-800-MEDICARE (1-800-633-4227), 24 hours a
day, 7 days a week. TTY users should call 1-877486-2048." Should it be noted that the calls are
free?

CMS declines to make this edit. SHIPs
can provide guidance to enrollees on all
of their enrollment options. The model
includes the flexibility to describe
additional state resources later in the
document.

CMS appreciates the suggestion.
However, this is the standard language
used for all Medicare Advantage models
and CMS plans to maintain it here for
consistency.

EOC Comments
Chapter Comment
Chapter Page 1, Section Header- Global comment for
1
proposed integrated ANOC and EOC
models: The content layout does not align
with the current D-SNP model. A health
plan sponsor recommended remaining
consistent with the current models as
creating a whole new format and content
creates risk in developing the documents and
increases time required to manage additional
models.

Chapter
1

Page 1, Section member handbook: Would
there be an approval process for state
changes to the integrated plan materials?

Response
CMS appreciates this comment but did not
make any changes in response to it. The
integrated ANOC and EOC models were
created based on the models used for the
Financial Alignment Initiative, which were
informed by consumer input and testing.
These models, similar to the Financial
Alignment Initiative models, are formatted
to provide all Medicare and Medicaid
information to enrollees in one document to
make it easier for these enrollees to
understand the benefits that are available to
them across both programs. While there are
some differences with the current D-SNP
ANOC and EOC models, CMS believes
they are differences that make the models
easier for beneficiaries to use. CMS will
consider additional consumer input, as well
as continue to review ways it can deliver
information in a more meaningful manner,
for future cycles.
The state will include state-specific
information in the model prior to the state
providing the models to plans. The models
will be subject to review by the state.

Chapter Comment
Chapter Page 1: Having the Handbook broken into
1
chapters rather than combined into one
document is problematic because it does not
allow for searching the entire document at
once unless the chapters are combined. For
the sake of consistency when replacing
terms or variables, it’s important to be able
to search the entire document. There are also
issues with the TOCs for each chapter (noted
later in this doc). When combining the
chapters, the section letters often default to
continuing the lettering from the previous
chapter, forcing manual corrections for the
section letters. These then need to be double
checked several times to ensure that the
formatting holds, because changes in one
area of the document can cause reversions or
updates in previous parts of the document. It
would be preferable to receive this document
in one piece rather than separate chapters, as
we do for other member materials.

Response
CMS understands the commenter’s concern
but has decided to keep the chapters separate
since it allows CMS to finalize chapters with
the state that are ready sooner than other
chapters that take more time. CMS will
consider ways to improve the process for
future cycles.
In addition, CMS is including some
guidance to assist with updates to the
chapter table of contents.
•
•
•
•
•
•

•
•

Chapter
1

Page 1, Section member handbook:
Consistent with the global comment above,
this is an example of an inconsistency
between the proposed integrated model vs.
the D-SNP model. In the D-SNP model,
plans are instructed to include “(Medicaid)”
when it is not part of the Medicaid agency
name. Would plans be required to do the
same for integrated plans?

Combine documents in Word
Check formatting is still correct
For each TOC, select the content the
plan wants to pull from and bookmark it
In each TOC, add the appropriate field
code to pull from that bookmark
Select all (Control A)
Update Field (page number only or
entire table depending on if changes
were made to the sections)
Continue these steps until all TOC’s
have updated
Save as a PDF document

AIP D-SNPs are not required to add
“(Medicaid)” after the Medicaid agency
name for this model because in section B2,
CMS explains that the state-specific name of
the Medicaid program is the name for the
Medicaid program run by the state. This is
how the state refers to the program, so CMS
uses the actual name of the program to be
more specific in this model and uses terms
the enrollee will be familiar with based on
interaction with Medicaid in a particular
state. CMS will consider additional
consumer input, as well as continue to
review ways to deliver information in a
more meaningful manner, for future cycles.

Chapter Comment
Chapter Page 1: Suggest aligning model more closely
1
to the CMS D-SNP EOC model in structure.
Specifically, aligning the TOC section,
chapter numbering, and names of the
sections and chapters would help
tremendously. Aligning the content to the
greatest extent possible would be helpful as
well.

Response
CMS declines to make this edit. This model
was created based on the models used for
the Financial Alignment Initiative, which
were informed by consumer input and
testing. CMS will consider additional
consumer input, as well as continue to
review ways to deliver information in a
more meaningful manner, for future cycles.

Chapter
1

This statement allows some flexibility for
benefit differences, such as when a benefit is
carved out of the plan for Medicaid.

Chapter
1

Page 2, Section Your Health and Drug
Coverage: Please clarify: When would
integrated plans not provide both sets of
benefits?
Page 3: Section member handbook introrecommends aligning with the D-SNP model
which eliminated the need to include a table
of contents (TOC) before every chapter.

Chapter
1

Page 3, Section Disclaimers: Are these
disclaimers different than the disclaimers
included in the D-SNP EOC model
instructions?

Chapter
1

Page 5, TOC: The TOCs throughout the
Handbook are problematic. Once the
chapters are combined into one document
(necessary to properly paginate) these TOCs
can no longer be auto-updated because each
one will list all of the headings for the entire
document rather than the specific chapter. If
you choose only to update the page numbers,
it works sometimes—but other times it auto
updates the entire table without asking if you
want to only update the page numbers.
Regardless, the chapter sections and
headings in the TOCs must be updated
manually, which increases the risk of error.

CMS rejects this edit. This model was
created based on the models used for the
Financial Alignment Initiative, which were
informed by consumer input and testing.
CMS will consider additional consumer
input, as well as continue to review ways to
deliver information in a more meaningful
manner, for future cycles.
The disclaimers included in the D-SNP EOC
model instructions are the same as the
disclaimers for MA plans that are required
in regulation and the Medicare
Communications and Marketing Guidelines
plus additional disclaimers required by the
state (including Medicaid regulations.)
CMS appreciates the comment but is
maintaining the format for the documents at
this time. CMS will consider changing the
formatting in a future cycle.
In addition, CMS is including some
guidance to assist with updates to the
chapter table of contents.
•
•
•
•
•

Combine documents in Word
Check formatting is still correct
For each TOC, select the content the
plan wants to pull from and bookmark it
In each TOC, add the appropriate field
code to pull from that bookmark
Select all (Control A)

Chapter Comment

Response
• Update Field (page number only or
entire table depending on if changes
were made to the sections)
• Continue these steps until all TOC’s
have updated
• Save as a PDF document

Chapter
1

Page 5, Section Chapter 1 Intro: Can this be
a single statement like "covers your
Medicare and Medicaid services"?
Page 6: Should this be “covers”? “Includes”
makes it sound as if the doctors and other
provides are a part of our plan, rather than a
part of our plan’s network. i.e., the plan and
the providers are separate entities.

This language should be included as directed
by the state.

Page 6: Could the word “over” be used here
instead? Our members prefer not to be
referred to as “older.”
Page 7, Section B - 2nd bullet point:
"Medicare and the State of …" The word
"state" should be lowercase as it is not a
proper noun. It would be capitalized if it
said Illinois State (which is a proper noun).
P7, Section A: Please consider combining
the intro paragraph that is included before
the TOC with Section A. The content for the
intro paragraph and section A is similar and
placing a short paragraph before the TOC
could be missed by members.

CMS appreciates the suggestion and has
updated the model with this change.

Chapter
1

P7, Section B2: recommends including
standardized content/language rather than
allowing input at a plan level.

The description may need to vary by state.
CMS has updated the language to state that,
“Plans may revise this section to best reflect
the coverage of the plan in the state.”

Chapter
1

P7, Section A: Please advise what
information should go here?

This is an optional section if the plan wants
to include additional information about the
plan. It is not required.

Chapter
1

Chapter
1
Chapter
1

Chapter
1

CMS appreciates the comment and does not
believe any edits are necessary. Plans have
the flexibility to adjust this language as
appropriate.

CMS appreciates the suggestion and has
accepted this edit.

CMS rejects this edit. Each chapter in the
EOC contains an introduction section so this
formatting is consistent throughout the
document.

Chapter Comment
Chapter P8, Section C: Recommends including
1
standardized content/language rather than
allowing input at a plan level.

Response
CMS declines to make this edit. For
example, there may be some states where
there are certain benefits that are carved out
and the language should be adjusted to
reflect this. CMS is revising this sentence to
state, “Plans may revise this section to best
reflect the coverage of the plan in the state”.

Chapter
1

CMS accepts this change.

Chapter
1
Chapter
1

Chapter
1
Chapter
1

Chapter
1

D, page 8: “Approved ZIP codes that are
excluded” is awkward; suggest deleting
“approved.”
P8, Section C: The plan recommends
changing "all" to "most."
P8, Section E: You are eligible for our plan
as long as you:
• Live in our service area (incarcerated
individuals are not considered living in the
geographic service area even if they are
physically located in it.), and
• Are age 21 and older at the time of
enrollment, and
• Have both Medicare Part A and Medicare
Part B, and
• Are currently eligible for Medicaid and
[insert language as appropriate under terms
of state contract], and
• Are a United States citizen or are lawfully
present in the United States.
P9, Section E: Recommend deleting this
bullet as it seems repetitive to the 3rd bullet
which references eligibility under the state
Medicaid program.
E, page 9, 4th bullet: We have a fairly
detailed list of these in our current program,
and being able to put this at the end of the
list after citizenship requirements would be
less confusing for members, so they don’t
have to parse sub-bullets and then jump back
to “citizen or lawfully present”.
E, page 9, second paragraph: Presently, our
state uses 60 days, which is similar to but
not exactly two months. However, we do not
want plans to choose a length; this needs to
be determined by Medicaid policy and
consistent across plans.

CMS accepts this change.
CMS has added language regarding
incarcerated individuals. The other eligible
requirements such as age restrictions can be
added as directed by the state.

CMS declines to make this edit. This
language is variable and can be adjusted as
directed by the state.
CMS has made the suggested edit and
moved the citizenship requirement up in the
list.

CMS has updated the language to allow
more flexibility for the use of days or
months for the deemed continuous eligibility
period.

Chapter Comment
Chapter Page 10: Can plans use health care provider
1
or primary care provider instead? We have
many mid-level providers (NPs, PAs, etc.)
who are not doctors who provide services for
our members.

Response
The instructions specifically note, "Plans
may change references to terms such as
“member,” “customer,” “beneficiary,
“member services,” “health risk
assessment”, “care coordinator,” “primary
care provider”, “prior authorization (PA)”,
“nursing facility”, and “urgently needed
care”, etc. as instructed by the state or based
on plan preference and update them
consistently throughout the Member
Handbook."

Chapter
1

This comment is outside of the scope of this
process. Please contact MMCO to further
discuss HRAs.

Chapter
1
Chapter
1

Page 10, Section F: This would be a change
for us and we are curious how it works.
What happens if a member ignores a mail
health risk assessment (HRA)? Is there a
penalty or a tracked performance measure
for plans? Are they expected to follow up by
other means?
P10, Section G2: Please clarify what
constitutes “other services”.

Chapter
1

Page 11, Section H - misspelling: "If you
already enrolled and are getting help form
one of these programs" - should be "from,
not "form"
P11, Section H: Please clarify the instruction
here. If plan has no monthly premium,
would plans delete the first bullet and all of
the content under section H1. Plan
Premium? Also, if plans delete, can plans
renumber the sections?

Chapter
1

Page 12: Is this the wrong section reference?
This is H2.

Chapter
1

Page 12: Can this section be deleted if plans
don’t have optional supplemental benefits?

Chapter
1

Page 12: Should this say that the call is
free? Also, should TTY number be
included?

CMS appreciates the request for
clarification. “Other services” is intended to
provide flexibility for services that can vary
by state or plan.
CMS has made this update.

CMS has updated this section to clarify the
instructions as requested.

CMS appreciates the comment and has
updated the language to reference the
appropriate section.
Yes, the instructions at the beginning of this
section note that plans should only include
the premium sections that apply for the
member.
CMS rejects this edit.

Chapter Comment
Chapter H3, page 12: At present, our plans can and
1
do offer some supplemental benefits at no
cost. We want to be sure the instructions are
flexible for plans to indicate a no-cost option
as well.

Chapter
1

Chapter
1
Chapter
1

Chapter
2

Chapter
2

Response
This section is describing optional
supplemental benefits that plans can choose
to offer under Medicare Advantage to
members at an additional cost. This section
is not describing supplemental benefits that
are included at no additional cost to
enrollees. These supplemental benefits
should be included in the benefits chart in
section D as described in the instructions to
this section.
P 12, Section I: Please clarify: Plans are
The plan may choose to make this language
usually effective from January 1 – December member-specific if the member enrolls later
31. Would there ever be a situation where
in the year or may use the dates January 1
plans would need to create non-calendar
and December 31 as well.
year materials?
Page 13, Section J: Member ID Card is not a CMS rejects this edit. Member ID Card
defined term so "card" should be lowercase. should be capitalized throughout since CMS
capitalizes the name of documents
throughout the model.
Page 13: Would it be possible to add an
CMS agrees with this update and have made
optional “most” in between get and services the change in the text.
here? Re: the direction below for plans to
include a separate description if there are
Medicaid services members must use a
different card for, it is possible and may
confuse members if we state this here
without the qualifier “most”.
Page 3, Section A. Bottom of page- Can
CMS declines to make this edit. We believe
these two sentences be combined? Example: that Section A outlines two separate ways
To learn more about coverage decisions,
for enrollees to obtain more information: 1)
refer to Chapter 9 of your member handbook calling the plan with questions about a
or contact Member Services.
coverage decision related to the enrollee’s
health care and 2) referring to Chapter 9 of
the Member Handbook for more information
about coverage decisions in general. CMS
believes it is helpful to keep the bullets
listed separately for enrollees
Page 3, Section A: Recommends remaining
CMS declines to make this edit. This model
consistent with the current DSNP model as
was created based on the models used for
creating a whole new format and content
the Financial Alignment Initiative, which
creates risk in developing the documents and were informed by consumer input and
increases time required to manage additional testing. These models, similar to the
models.
Financial Alignment Initiative models, are
formatted to provide all Medicare and
Medicaid information to enrollees in one

Chapter Comment

Chapter
2

Page 4, 3rd hollow bullet last sentence:
recommend changing "got to" to "received
from".

Chapter
2

Page 6, Section B.: Recommend allowing
flexibility to modify this section.

Chapter
2

Page 6, Section B: Recommend giving plans
flexibility based on specific services and
eligibility requirements if applicable.

Chapter
2

Page 7, Section C: Our state currently offers
contact information for additional resources
before the SHIP, such as a nurse advice line
and a behavioral health crisis line. While
these could be moved to Section J instead,
we believe the flow of the document and
their relative importance warrant placement
just after the care coordinator.
Page 10, beginning of Section F: We would
prefer to have the state-specific name written
out in the first instance of the text as well as
the title, if possible.

Chapter
2

Chapter
2

Page 10: We believe this is a web link for
Medi-Cal and should not be included here.

Chapter
2

Page 10, Section F, first sentence: We
would prefer to have the state-specific name
written out in the first instance of the text as
well as the title, if possible

Response
document to make it easier for these
enrollees to understand the benefits that are
available to them across both programs.
CMS will consider additional consumer
input, as well as continue to review ways it
can deliver information in a more
meaningful manner, for future cycles.
Updated the language to state, “You can also
make a complaint to us or to the Quality
Improvement Organization about the quality
of the care you received”.
The instructions to this section currently
state that plans can modify this section as
appropriate.
CMS has adjusted this language to describe
LTSS as applicable.
CMS appreciates the comment; however,
CMS believes it is important to include the
SHIP information early in this section so
that enrollees have access to unbiased
information on their health care options.

CMS has adjusted the language to note that
the name of the Medicaid program should be
included. Also, the instructions at the
beginning of this section give states the
ability to adjust this section to accurately
describe the Medicaid program.
CMS has deleted the web link.
CMS has adjusted the language to note that
the name of the Medicaid program should be
included. Also, the instructions at the
beginning of this section give states the
ability to adjust this section to accurately
describe the Medicaid program.

Chapter Comment
Chapter Page 11, Section G: The D-SNP model EOC
2
includes a placeholder for state-specific
long-term care (LTC) ombudsmen program.
Is this not applicable to integrated plans?

Response
CMS has added the LTC Ombudsperson to
this section.

Chapter
2

Page12, Section H1: The D-SNP EOC
Model includes the following language:
[Other plans should use this language: Most
of our members qualify for and are already
getting “Extra Help” from Medicare to pay
for their prescription drug plan costs.] Is this
not applicable?

Chapter
2

Page 13, Section H2: The D-SNP EOC
model includes a table for the state
pharmacy assistance program (SPAP)
contact information. Is that not applicable
here?
Page 14, Section I: The D-SNP EOC model
includes a “How to contact the Railroad
Retirement Board” and “Do you have
“group insurance” or other health insurance
form an employer?”, do these sections not
apply to integrated plans?

All of the members enrolled in these
integrated AIP D-SNPs will receive Extra
Help, so this statement is not applicable.
CMS appreciates this edit but did not add
the suggested language from the D-SNP
ANOC and EOC models because it is not
applicable to dually eligible enrollees and
these enrollees may find it confusing. In the
AIP D-SNP ANOC and EOC models, CMS
is working to better tailor language to dually
eligible individuals.
The SPAP section mirrors the language
included in the D-SNP EOC. The
instructions of this section do note that plans
can modify this section to include contact
information for resources.
CMS has added this information.

Chapter
2

Chapter
2
Chapter
2

Page 15, Section J: Suggest using acronym
CMS has added the acronym.
for ESRD
Page 15, Section J, Other Resources: Are we CMS has added this language.
no longer required to include information
about the Rail Road board? That is currently
part of the section in the non-integrated EOC

Chapter
3

Page 4, Section A: We believe it would be
clearer to introduce the acronym the first
time the term is used….
Page 5, Section B: Suggest using "provided"
instead of "furnished" in bullet point
beginning with, "•You must get your care
from network providers."
Page 10, Section F: Recommend adding new
language to address the subject more
completely and accurately.

Chapter
3
Chapter
3

CMS has made this update.
CMS has made this update.

CMS rejects this edit. Behavioral health
services provided are very different from
state to state. The state may provide model
language for D-SNPs to use as appropriate.

Chapter Comment
Chapter Page 13, Section I3: Lowercase governor
3
and president as both are common nouns.

Response
CMS has made this update.

Chapter
3

Page 15, Section J1: Last paragraph: Suggest
change to 2nd sentence for clarity. Either: "If
you go over the limit,” Or “If you use
services over the benefit limit,”.
Page 17: Would it be possible to add
optional language here to indicate that it’s
the plan that rents the equipment for the
member for plans that don’t have member
copays?
Page 17: If members do not make payments
for DME under the plan because of
Medicaid coverage, then all of this section
can be modified to make it clear that the plan
rather than the member is paying, correct?
Page 18: 2024?

CMS has updated this language.

Page 17, Section M1: Recommend
flexibility to describe DME coverage per
State law.
One commenter suggested including
numbers instead of writing out numbers.

CMS has added the flexibility for the state to
modify this section.

Chapter
4

Page 1, TOC, Instructions: Should be
updated to note that plans can update the
content for the Table of Contents.

Chapter
4

Page 2, Section A - 2nd paragraph: Missing
the word, "you". "For some services, are
charged an out-of-pocket cost called a
copay."
Page 2, Section A: Because some D-SNP
members do have copays for Part D drugs
(which are not described in this chapter), it
might help to specify “covered medical
services” here just to make it clear that we
are not referring to absolutely everything.
And maybe even add a sentence to this
paragraph that tells them which chapter to go
to for info about Part D drug costs.

The instructions for the TOC do note that
plans must update the TOC to accurately
reflect the information is found on each
page.
CMS has added the word "you" to Chapter
4.

Chapter
3

Chapter
3

Chapter
3
Chapter
3
Chapter
4

Chapter
4

CMS has added flexibility for the state to
modify this section.

CMS has added a sentence at the beginning
of this section for the state to modify it
based on member coverage.
CMS has made this update.

CMS rejects this edit as the standard
formatting is to include writing out numbers.

There is language in the first paragraph that
notes that information about drug benefits is
found in Chapter 5. Some of these services
may not be considered as “medical” services
which is why this language is general.

Chapter Comment
Response
Chapter Page 3, Section C - bullet with apple icon: It CMs has made this update.
4
reads better, "You will find this apple next to
preventive services in the Benefits Chart."
Chapter
4

Chapter
4

Chapter
4

Page 3: The wording here is problematic
because it isn’t a referral that’s needed to see
an out-of-network provider, it’s an
authorization. The plan (not the provider)
can give a member an authorization to see an
out-of-network provider. Referrals are
different and some plans are direct access
plans and do not require referrals to see
specialists, etc.
Page 3, Section A: It looks like coinsurance
language (a % of costs rather than fixed
copays) was removed. This does not affect
our state at the moment, but we wonder
whether it should be added back for program
flexibility in other states. It is still mentioned
in Chapter 8.

P.4, Section C: The instructions mention
special supplemental benefits for the
chronically ill (SSBCI) but do not mention
value-based insurance design (VBID)
benefits - recommend adding for D-SNPs
that file VBID to include the required
wellness and health care planning (WHP)
language.

CMS appreciates the comment but did not
make a change as a result of it. This section
of Chapter 4 separately addresses both
referrals and prior authorization. Referrals
are addressed two bullets above prior
authorization.

CMS removed cost-sharing language in
Section A of Chapter 4 because AIP D-SNPs
enroll only people who are full benefit dual
eligible individuals (Qualified Medicare
Beneficiary Plus, Specified Low-Income
Medicare Beneficiary Plus and other fullbenefit dually eligible individuals). For all
Medicare Part A and B services, costsharing is either $0 or the Medicaid copay
applicable to that service (if the state charges
such copays and the affiliated Medicaid plan
does not waive such copays). For Part D, the
copay is one of the LIS level copays for full
LIS until catastrophic coverage, where there
is no cost-sharing.
CMS has deleted the reference to
coinsurance in Chapter 8 since it is not
applicable.
CMS has added language for VBID benefits.

Chapter Comment
Chapter Page 4: Would it be possible to move the list
4
of chronic conditions into the actual Benefits
Chart? It seems odd to have that information
here, and then in the chart, plans have to
refer them back to this page to see what
conditions are eligible.

Response
CMS will consider this suggestion for a
future cycle.

Chapter
4

CMS has added a variable field for states to
add information on any continuity of care
requirements.

Chapter
4
Chapter
4

Chapter
4

Page 4, Section C, 4th bullet: Between this
bullet and the next, our 2023 models include
details about a continuity of care period and
using existing providers. There was a brief
instruction about it in Chapter 1, but we
believe it needs further elaboration here, for
states that have it. This is very important to
our program at present and is likely to be
carried forward into any successors. It will
be important for members to be able to keep
going to their existing providers for the first
X days (presently 180) that they enroll in
this program, and we need a space for plans
to describe that.
Page 5, 1st bullet: Currently plans are also
able to write "prior authorization (PA) may
be required" in this section. Is that still going
to be allowed?
Page 6, Section D: Our Plan’s Benefits
Chart. In the Services That Our Plan Pays
For chart beginning on page 6, there is some
confusion about what a plan should do, and
where the benefits should be listed, if the
plan offers more services for a specific
benefit, such as acupuncture, in the
supplemental benefit, than it does in the
Medicare-defined benefit. In short, if a
supplemental benefit exceeds the Medicaredefined benefit, how and where should that
be listed?
Page 6, Section C: This – and many other
changes – are likely to be extensive. If states
do not have the opportunity to modify these
models before sharing them with our plans,
how does CMS expect us to instruct or
communicate these changes to plans and
ensure consistency and accuracy in the
handbooks?

CMS rejects this update. Plans should
clearly indicate any PA requirements.
If the plan offers more services for a specific
benefit, for example if they offer unlimited
acupuncture benefits, then they should
update the language in the benefits chart to
reflect the actual benefits that are covered
for the plan and note that the coverage is
unlimited. If a plan offers additional benefits
that are not listed, then they should add
those benefits to the description.

The state will have the opportunity to work
with CMS and modify language related to
Medicaid prior to sharing the model with the
D-SNPs in the state.

Chapter Comment
Chapter Page 6, Section C: We anticipate directing
4
plans to do this, assuming HCBS services
continue to be included in 2024. We believe
it was clearer to keep this as its own bullet,
but we thank CMS for including it here.
Chapter Page 6, Section D: The plan requests
4
flexibility to modify the benefit chart
appropriately to describe the integrated
plans. The current structure does not allow
flexibility for plans to fully integrate
disclosures for supplemental Medicare
benefits or for situations in which Medicare
and Medicaid coverage may differ. For
example, the benefits chart specifies visit
limits for acupuncture and limits services to
low back pain. California Medicaid,
however, allows for coverage as medically
necessary and does not limit services to
treatment of low back pain. Members would
benefit from flexibility by plans to integrate
coverage descriptions to allow for a
comprehensive description for enrollees.
Chapter Page 7, Section D: If a plan’s supplemental
4
benefit is BETTER than the Medicare
defined benefit (example Acupuncture) can
plan remove the language and add the
supplement benefit? Or should the
supplement benefit be added to the same
section, but under the Medicare benefit? We
sometimes offer unlimited acupuncture and
had questions on this benefit with the CA
exclusively aligned enrollment (EAE) DSNP.
Chapter Page 7: In other places, numerals have been
4
used even for numbers below 10 (e.g., see
highlighted use of 8 under Acupuncture
above). Would it be possible to do that here
(use 4) and throughout to be consistent?
Numerals, from a health literacy standpoint,
are easier to read and comprehend for many
people.
Chapter Page 7, Acupuncture: Should probably say,
4
"only if you have chronic lower back pain"

Response
CMS appreciates the comment.

CMS has included an instruction at the
beginning of this section noting that plans
should modify this section throughout to
reflect Medicaid or plan-covered
supplemental benefits.

If the plan offers more services for a specific
benefit, for example if they offer unlimited
acupuncture benefits, then they should
update the language in the benefits chart to
reflect the actual benefits that are covered
for the plan and note that the coverage is
unlimited. If a plan offers additional benefits
that are not listed, then they should add
those benefits to the description.
Thank you for pointing out the
inconsistency. CMS spells out numbers one
through ten.

CMS rejects this change. This is standard
language used for all Medicare models.

Chapter Comment
Chapter Page 8, Ambulance: This paragraph should
4
be the last paragraph as it sounds like it is
for "non-emergent" transportation by
ambulance.

Response
CMS agrees that this language should be
moved to the last paragraph and adopted the
change.

Chapter
4

CMS agrees and have made this update.

Chapter
4
Chapter
4

Page 8, Annual Wellness Visit: This is
different than the current EOC. The current
EOC has the caveat, "Note: the first annual
wellness visit can't take place within 12
months of your "Welcome to Medicare"
preventative visit. However, you don't need
to have a "Welcome to Medicare" visit to be
covered by annual wellness visits after
you've had Part B for 12 months. Is this
caveat still going to apply?
Page 8, Cardiac (heart) rehabilitation
services: Modify second sentence to read,
"Members must meet certain conditions and
have a doctor's...."
Page 8, Acupuncture: Our state is
considering how pregnancy and pregnant
members might interact with this program,
and we believe that the care coordination
services offered in this program would be
beneficial. However, pregnancy-related
services are barely mentioned in this model,
perhaps because they are not thought of as a
typical Medicare service. Prenatal care,
delivery/childbirth, and post-natal care are
just a few examples of the kind of detail we
might need to add to this table in order to
accurately describe “any Medicaid benefits”
as directed above. We are flagging this so
CMS can consider whether instructions in
this draft are sufficient and flexible enough.

Thank you. CMS has updated this language.

Yes, the state has the flexibility to add any
Medicaid-covered benefits to this chart as
described in the instructions for the chart.

Chapter Comment
Chapter Page 10, Section D: Colorectal cancer
4
screening: lowercase colonoscopy, Family
planning services: lowercase contraception,
Health and wellness education programs:
misspelling of "fitness" , Hospice care:
capitalize Member Services, Medicare Part
B prescription drugs (continued) - remove
the duplicate word "not" , Outpatient
rehabilitation services: misspelling of
Medicaid, Physician/provider services,
including doctor’s office visits (continued):
suggest using acronyms.
Chapter Page 11: The current recommendation is for
4
people 45 and over. Can this be updated to
be consistent with that?

Response
Thank you for these comments. CMS has
made several updates throughout this
section.

Thanks for this comment. CMS updated
Chapter 4 consistent with the recently
revised policy recommendations by the U.S.
Preventive Services Task Force that
Medicare reduce the minimum age for
colorectal cancer screening from 50 to 45
years.

Chapter
4

Page 11, Depression Screening: Is there a
CMS has added the “or” back in the
reason that "Can provide follow-up
sentence.
treatment and referrals" was removed? Many
primary care settings do the screening and
then make a referral for treatment. They
don't always provide the treatment. Suggest
adding "or" back in.

Chapter
4

Page 12, Dental: We appreciate this. The
interaction of this program with dental
benefits in our state requires more
explanation.
Page 16, Family Planning Services: Should
we clarify that this can either be a provider
that is in network or out of network?

Chapter
4

CMS appreciates the comment.

CMS appreciates the comment, but the
existing language in Chapter 4, Family
Planning Services makes this point as
currently worded. However, CMS is
revising the language further for clarity to
state: “The law lets you choose any
provider – whether a network provider or
out-of-network provider – for certain
family planning services. This means any
doctor, clinic, hospital, pharmacy or
family planning office.”

Chapter Comment
Chapter Page 21: Hospice provider/Original
4
Medicare pays for this:
Original Medicare will be billed for your
hospice care, even if you’re in a Medicare
Advantage Plan. When you get hospice care,
your Medicare Advantage Plan can still
cover services that aren’t a part of your
terminal illness or any conditions related to
your terminal illness.
Chapter 4: An MA enrollee who elects
hospice care, but chooses not to disenroll
from the plan, is entitled to continue to
receive through the plan any MA benefits
other than those that are the responsibility of
the hospice. Under such circumstances, the
MA plan is paid a reduced capitation rate for
that enrollee by CMS and the MA plan is
responsible for continued coverage of
supplemental benefits. CMS pays: (a) the
hospice program for hospice care furnished
to the enrollee and (b) the MA plan,
providers, and suppliers for other Medicarecovered services furnished to the enrollee
through the original Medicare program,
subject to the usual rules of payment.
Chapter Page 21, Section Home health: Recommend
4
removing or modifying the language in
parenthesis to clarify as coverage is based on
medical necessity:
We pay for the following services, and
maybe other services not listed here:
• Part-time or intermittent skilled nursing
and home health aide services. (To be
covered under the home health care benefit,
your skilled nursing and home health aide
services combined must total fewer than 8
hours per day and 35 hours per week.)
Chapter Page 25, Inpatient stay, covered services in a
4
hospital or skilled nursing facility (SNF):
The previous language was clearer, "If you
have exhausted your inpatient benefits or if
the inpatient stay is not reasonable or
necessary, we will not cover your inpatient
stay. However, in some cases we will cover

Response
CMS has made a small adjustment to the
language to note these are covered services.

CMS declines to make this edit as this
section appropriately describes the benefit.

CMS has updated the language to clarify the
inpatient stay benefit limitations.

Chapter Comment
certain services you receive while you are in
the hospital or the SNF.

Response

Chapter
4

The instructions at the beginning of section
D of chapter 4 includes the following
language which provides flexibility for the
state to adjust the cost-sharing as needed,
“[Plans should modify this section

Chapter
4
Chapter
4
Chapter
4

Chapter
4

Page 29, Nursing Facility (NF) Care: In our
state, it is difficult to calculate copays
because they depend on income. We would
prefer to be able to refer members to their
care coordinator or some other resource for
help, or at least specify some standard
language for our plans to use. Something
like, “Please contact us at the number at the
bottom of the page to learn if you will need
to contribute toward your nursing home
care.”

Page 29, NF Care: As allowed in Chapter 1,
our state is likely to modify this to read,
“Nursing home care,” potentially without
using the NF acronym.
Page 29, NF Care: It does not look like this
acronym is used again, so should it be
removed?
Page 47, Section E: Supplemental Dental,
vision, hearing - chart instructs plan to place
supplemental benefit in Section E. But the
title for Section E is "Supplemental benefits
you can buy" and instructions do not say we
can revise the title when supplement benefits
have no extra premium. Should plans be
adding free supp benefits to the medical
chart, or Section E?
Page 48, Section E: As noted earlier, our
state currently has plans offering some
supplemental benefits at no cost. If possible,
we would like to make sure the model is
flexible to allow this in 2024 as well,
potentially by modifying instructions to
specifically address $0 copays or benefits at
no cost.

throughout to reflect Medicaid or plancovered supplemental benefits as
appropriate as well as any copays that may
differ for Medicaid.]”

CMS has left copay fields variable so the
state should include the actual copay or
possible range for copays and then can add
additional instructions if needed.
This is an acceptable modification.

A plan can remove an acronym if a term is
only used once in a document.
The dental instructions note that optional
supplemental benefits should be included in
Section E, “Extra “Optional Supplemental”
benefits you can buy” rather than
the included supplemental benefits section.
CMS has further clarified this language. The
plan should only include Section E if the
plan offers extra optional supplemental
benefits that you can buy as described in the
instructions for section E.
Per the instructions, the plan should include
supplemental benefits that are no cost in the
table above. Section E is for optional
supplemental benefits that are an additional
cost. The plan should only include section E
if the plan offers extra optional supplemental
benefits that you can buy as described in the
instructions for section E.

Chapter Comment
Chapter Page 48, Section E: Example of above: If
4
members do not have to pay an additional
premium, should the title of the section be
“...benefits you can get” instead of
“…benefits you can buy”?

Response
No, this section is for optional supplemental
benefits that are an additional cost. If there
are no supplemental benefits that are at an
additional cost then plans should not include
this section per the instructions.

Chapter
4

Page 49: The previous chart found in the CY
2023 D-SNP EOC which outlines what is
not covered under any conditions or under
any circumstances is more user friendly and
easier to read. Suggest using the CY 2023
formatting in this section.

CMS rejects this edit but will consider it in a
future cycle.

Chapter
4
Chapter
4

Page 49, Section H: Missing word "pay".

CMS has made this edit.

Page 49, Section G: We have some
Medicaid-covered services we would like to
include here, such as dental and nonemergency transportation. It looks like plans
“should modify” this section to include
them, but, similar to an earlier comment,
how can we ensure consistent descriptions
across plans?
Page 49, Section G1: The content here
seems to be similar to the content written in
the benefits chart. Would it be possible to
combine this with the language in the
benefits chart?
Page 4, Section A2: For consistency,
Chapter 1 introduces this as Member ID
card. Suggest changing for consistency.
Page 4, Section A.2.: This is a very high
standard.
Page 10, Section B1. Drugs on our Drug
List: The below statement in Section B1 will
be an issue for some plans, as some plans
operate in states where outpatient drugs are
carved out of Medicaid plans and
administered directly by the state or another
entity. Our Drug List includes drugs covered
under Medicare Part D and some
prescription and over-the-counter (OTC)
drugs and products covered under [Insert
name of state Medicaid program].

Since this is a variable field, the state can
modify this section as appropriate and
provide the information to the plans in the
state.

Chapter
4

Chapter
5
Chapter
5
Chapter
5

CMS rejects this edit. This section describes
benefits covered outside of the plan.

CMS agrees and has made this update.
Thanks for the comment. CMS has not made
any changes to the language.
CMS has added language to give states the
flexibility to modify this language.

Chapter Comment
Chapter Page 10: The drug list is not always mailed.
5
The requirement is to send an electronic
notice that tells members where they can
access the document online. Could “we sent
you in the mail” either be bracketed or
removed?
Chapter Page 10, Section B.1: This statement will be
5
an issue for D-SNPs in California, since
outpatient drug benefits are carved-out of
Medi-Cal (Medicaid) managed care
organizations and administered directly by
the State.
Chapter Page 11, Section B3, Drugs Not on our Drug
5
List: It would not be feasible to list all
excluded drugs (page 11). Is CMS expecting
plans to list all excluded drugs? The below
statement implies plans need to list all
excluded drugs. Our plan does not pay for
the drugs listed in this section. These are
called excluded drugs. If you get a
prescription for an excluded drug, you may
need to pay for it yourself. If you think we
should pay for an excluded drug because of
your case, you can make an appeal. Refer to
Chapter 9 of your Member Handbook for
more information about appeals.

Response
CMS has made this language variable.

CMS has added language to give states the
flexibility to modify this language.

CMS does not expect D-SNPs to list all
excluded drugs. CMS has modified the
language to state, “Our plan does not pay for
the kinds of drugs described in this section.”

Chapter Comment
Chapter Page 11, Section B3, Drugs Not on our Drug
5
List. Plans have the ability to cover drugs
outside of Part D, which some plans are
doing. CMS has listed some drugs as
examples of excluded drugs (page 11),
which health plans may cover outside of Part
D. Listing of drugs the health plans may
cover outside of Part D, as done in the
statement below, may lead to beneficiary
confusion over what drugs the health plan
covers. Also, by law, Medicare or [Insert
name of Medicaid program] cannot cover
the types of drugs listed below.
• Drugs used to promote fertility
• Drugs used for cosmetic purposes or to
promote hair growth
• Drugs used for the treatment of sexual or
erectile dysfunction, such as Viagra®,
Cialis®, Levitra®, and Caverject®
• Outpatient drugs made by a company that
says you must have tests or services
done only by them
Chapter Page 11, Section B.3: It is not feasible to list
5
every excluded drug. Is that what CMS is
expecting here?
Chapter
5

Chapter
5
Chapter
5

Page 11, Section B.3: CMS should remove
erectile dysfunction drugs from this list,
since plans can cover these drugs outside of
Part D. Keeping this would confuse
beneficiaries who do have that coverage.
Page 11, Section B4: Recommend flexibility
to remove Section B4 to align with the Part
D Defined Standard benefit that is filed in
the PBPs
Page 14, Section D1: Would like this to
match the continuity of care period for new
members if possible, and definitely not to
vary across plans.
In our state right now, it must be 180 days.
While 180 is greater than 90, how can we
communicate to our plans that it must be 180
and is not variable across plans?

Response
CMS has updated the instructions for this
section to note that plans can modify this
section when the drugs are covered by
Medicaid or as a supplemental benefit.

CMS does not expect plans to list all
excluded drugs and has modified the
language to state, “Our plan does not pay for
the kinds of drugs described in this section.”
CMS has modified the instructions for this
section to note that plans can modify this
section when the drugs are covered by
Medicaid or as a supplemental benefit.
CMS has updated the language to allow
plans that do not use drug tiers to omit this
section.
CMS appreciates this comment. Please note
that the state has the flexibility to modify the
language based on state requirements since
it is variable. The state will then send the
EOC to the AIP D-SNPs in that state.

Chapter Comment
Chapter Page 16: The term many plans use here is
5
authorization rather than approval. Can that
be an option here?
Chapter Page 18, Section F2: Change pronoun to
5
"its" refers to facility not people
Chapter Page 1: Perhaps this should this be optional
6
text?
Chapter Page 1, Chapter Intro: Recommend
6
flexibility to remove the bullet about tiers in
the Introduction to align with the Part D
Defined Standard benefit.
Chapter Page 5, Section B: Recommend flexibility to
6
remove the sentence about Catastrophic
Coverage to align with the to align with the
Part D Defined Standard benefit
Chapter Page 5, Section B: For consistency, Chapter
6
1 introduces this as Member ID card.
Chapter Pages 5-6: It seems that these two items
6
should have been sub bullets of the previous
item.
Chapter Page 6, Section C: Recommend flexibility to
6
add language from the D-SNP ANOC and
EOC models to describe the Defined
Standard benefit and cost-sharing if a
member loses LIS. This includes four drug
stages, no drug tiers, and cost-sharing for
Defined Standard coverage stages.

Chapter
6

Page 7, Section C1: Plan instructions should
include plans that have only 1 Tier with no
Cost Share. Model should make allowances
for those PBPs that would be filed as
Defined Standard and would not having a
tiering structure and remove all instances to
tiering; to include would more than likely
cause member confusion as their formulary
will have no tiering information.

Response
Yes, the instructions in Section 1 note that
plans can modify these types of terms as
applicable.
CMS accepts this edit.
CMS has made this language variable.
CMS has modified the instructions so that
plans can omit if not applicable.
The instructions already allow the ability to
delete the last two sentences if there is no
Part D cost-sharing.
CMS has modified this language.
CMS has modified the formatting for this
section.
CMS declines to make this edit. This model
is only for AIP D-SNPs. Dually eligible
individuals are deemed or redeemed eligible
for LIS for the next plan year starting in July
of the prior year. That means an individual
who has lost Medicaid in the prior year and
who is not redeemed LIS-eligible for the
coming plan year would have exhausted any
period of deemed SNP LIS eligibility
(maximum length is 180 days) by January 1
of the plan year. Since LIS eligibility lasts
for the full plan year, even if the individual
loses Medicaid during the plan year, all DSNP enrollees will retain LIS eligibility for
the full plan year (January-December).
CMS has updated this language to allow this
section to be deleted if there is no costsharing.

Chapter
Chapter
6
Chapter
6

Chapter
6

Chapter
6
Chapter
6
Chapter
7
Chapter
7
Chapter
7

Chapter
7

Comment
Page 13: Can this be updated for 2024 copay
amount?
Page 14, Section G: We don’t think any of
our members will be eligible for ADAP
because in our state, Medicaid eligibility
seems to disqualify members from ADAP.
Can we make this section optional? See this
website: https://scdhec.gov/aids-drugassistance-program.
Our HIV/AIDS waiver does offer some
additional covered prescriptions to members
with HIV/AIDS, so if this section is not
optional, could we modify it to include
details about the waiver instead?
Page 14: Shouldn’t this section be updated
with the vaccine info from the September 6,
2022, HPMS memos “Updates to Part D
Member Materials for Contract Year 2023”
and “Additional Part D Updates to Contract
Year 2023 Member Material Models for
Medicare-Medicaid Plans and Minnesota
Senior Health Options Plans?”
Page 15: Aren’t all Part D vaccines covered
at no cost now?
Page 16, Section H1: Change verb "work" to
"works".
Page 2, Section A: Capitalize Member
Services for consistency.
Page 2, Section A: For consistency, Chapter
1 introduces this as Member ID card.
Page 2, Section A, 2nd sub bullet under 2nd
bullet: Currently, our handbooks refer to
member services or our program
ombudsman. Understanding that the role of
the ombudsman is still a bit TBD going
forward, it would still be nice to include the
option in the instructions
Page 3: Something seems to be missing here.
This is a run-on sentence. Maybe just add
“and” between the two clauses?

Response
Yes, the instructions allow the copay
amounts to be updated.
Yes, the instructions indicate that this
section is optional.

CMS has updated the section to reflect the
Inflation Reduction Act requirements.

CMS has updated the language to correctly
reflect vaccine coverage.
CMS has made this update.
CMS has made this update.
CMS has updated the language to Member
ID card.
CMS has added this option.

CMS has updated this sentence.

Chapter Comment
Chapter Page 3, Section A, Bullet 1: We flagged this
7
for discussion within our state. We hope that
CMS will allow us the freedom to set retro
enrollment policies that align with what we
currently use in our Medicaid managed care
program.

Response
This is outside of the scope of the Federal
Register notice. Please contact MMCO to
further discuss these policies.

Chapter
7

Page 4, Section A, Bullet 2: Grammar item.
“In only a few cases, we will” (with comma)
or, “In only a few cases will we” (no
comma).
Page 4, Section A6: The D-SNP EOC model
includes the following instruction: [Plans
should insert additional circumstances under
which they will accept a paper claim from a
member.] Does this not apply to integrated
plans?
Page 5, Section B: Suggest adding the word
"covered" to make clear only covered
services will be reimbursed.
Page 5, Section B: Missing the word "for"
"you may also call us to ask for payment".
Page 5, Section B: Suggest using
"timeframe" instead of "days" as it could be
years.
Page 1, Section B: Please clarify what
minimum access to care means?
Page 3: Would it make more sense to refer
them to the number at the bottom of the page
as we do in other places? They would also
be able to access an interpreter or use the
TTY numbers if we did that.

CMS has updated this language.

Page 4, Section B: Suggest using "You"
instead of women for gender inclusive
language.
Page 5, Section C: Remove "to” from 3rd
paragraph as not needed.
Page 5, Section C1: Add bullet underneath
here: Healthcare operations per HIPPA.

CMS has edited this sentence.

Page 6: Can we refer members to the
number at the bottom of the page if that is
the correct number?
Page 10, Section H1: Italicize "Member
Handbook".

CMS has changed this to read Member
Services.

Chapter
7

Chapter
7
Chapter
7
Chapter
7
Chapter
8
Chapter
8

Chapter
8
Chapter
8
Chapter
8
Chapter
8
Chapter
8

CMS rejects this edit. The circumstances
may vary by state in some situations so
CMS is leaving this language more general.

CMS rejects this edit because the section
instructions include variability to add this
information.
CMS has made this edit.
CMS has made this edit.
This is the baseline for what plans are
required to provide for access to care.
CMS has updated this to include Member
Services but have also left the ability to
write the plan.

CMS has made this edit.
CMS rejects this edit.

Member Handbook is italicized.

Chapter
Chapter
8
Chapter
8
Chapter
8
Chapter
8

Chapter
8
Chapter
8

Chapter
9
Chapter
9

Chapter
9
Chapter
9
Chapter
9

Comment
Page 10, Section I: For consistency, Chapter
1 introduces this as Member ID card.
Page 10: Refer them to the number at the
bottom of the page?
P.10, Section H1: Please clarify. Why
wouldn’t plans list their respective state
agency here?
P.10, Section H1: Please confirm what “if
applicable” means here. Should this bullet be
included if there is an Ombudsmen
designated for this service area.

Response
CMS has updated this language.

Page 11, Section I: There was a reference to
coinsurance in Chapter 2 in 2023, but it was
removed in this set of documents. Be sure
these two chapters align.
Page 12: For 2023 and previous years, we
have noted that members may face estate
recovery in some circumstances, and we
have included that information as a bullet
before this one. Depending on program
design, it is possible this might continue into
2024; is it OK for the handbook to be silent
on the issue, or should the instructions be
modified to allow states to insert it here if
needed?
Page 1: Should call out that this section can
be used as a guide for how members can file
an appeal.
Page 1 - first instruction: Our state has
always had a paragraph here referring people
to our ombudsman as a resource for appeals.
Assuming they remain in that role for 2024,
should we add an instruction here or is this
addressed adequately elsewhere?
Page 5: Could this say “the following chart”
since it won’t necessarily be “below”
depending on page breaks?
Page 7, Section E2: Please confirm, should
expedited and fast appeal be in quotation
marks?
Page 7, Section E2: Suggest adding the
following language as the last sentence as
many services are covered by both Medicare

CMS has removed this information in
Chapter 2.

CMS changed this to read Member Services.
CMS has updated this language.
Yes, that is correct. The bullet should be
included if there is an Ombudsperson
designated for the service area.

The instructions to this section specifically
indicate, “Plans may add information about
estate recovery and other requirements
mandated by the state.”

CMS rejects this edit. The draft does note
that it includes what to do if there is a
disagreement with a decision.
The instructions give the state the flexibility
to add information about the ombudsperson.

CMS has made this update.
CMS has made this update.
CMS has added this language.

Chapter Comment
and Medicaid - “If your problem is about a
coverage of a service or item covered by
both Medicare and Medicaid, the letter will
give you information regarding both types of
Level 2 appeals.”
Chapter Page 8: Because these parentheses are inside
9
another set of parentheses, they should be
changed to square brackets to avoid
confusion for reader. Alternatively, the
parentheses around the whole sentence could
be removed.
Chapter Page 10: "Refer" should be lowercase.
9
Chapter Page 11: I believe the bullet styles here
9
should be swapped: this should be a first
level bullet and the next two should be
second level bullets.
Chapter Page 12: Do we need to have the phone
9
number listed in both of these places, one
right after the other? If the number is the
same, can we make note of that instead?
Chapter Page 12: I don’t understand how this
9
sentence works if you don’t include the
second optional part? It appears to be
incomplete.
Chapter Page 12: Does this item need to be bulleted?
9
If so, shouldn’t it be a first level bullet?
Chapter Page 12, Section F3: AIP plans require
9
appointment of representative in this
scenario. Suggest removing “insert as
applicable.”
Chapter Page 12, Section F3: Under the Part D
9
section, these 3 paragraphs are bulleted.
Should they be bulleted here?
Chapter Page 12, Section F3: There is no guarantee
9
that a member requesting an expedited
appeal will receive one. While the second
bullet states the process for a fast appeal is
the same as for a fast coverage decision, the
commenter believes it would be more
member friendly to include similar language
as coverage decision.
We automatically give you a fast appeal if
your doctor tells us your health requires it. If

Response

CMS rejects this update.

CMS has made this update.
CMS has made this update.

The section includes variable language is for
any additional contact information, as
applicable.
CMS has edited the language to make the
whole bullet optional.
CMS has made this update.
CMS has removed this language.

CMS has made this update.
CMS has updated the language in this
section.

Chapter Comment
you ask without your doctor’s support, we
decide if you get a fast appeal. If we decide
that your health doesn’t meet the
requirements for a fast appeal, we send you a
letter that says so and we use the standard
deadlines instead. The letter tells you:
• We automatically give you a fast appeal if
your doctor asks for it.
• How you can file a “fast complaint” about
our decision to give you a standard appeal
decision instead of a fast appeal decision.
For more information about making a
complaint, including a fast complaint, refer
to Section K [insert reference, as applicable].
Chapter Page 13, Section F3: Suggest replacing
9
“medication” with “item” to be consistent
with previous bullets.
Chapter Page 19: Not italic
9
Chapter Page 19, Section F5: Italicize "Member
9
Handbook"
Chapter Page 27, Section G5: Suggest changing this
9
to “appeal”.
Chapter Page 29, Section G5: Should these bullets be
9
sub-bullets to bullet 1?
Chapter Page 29, Section G6: Grammatical
9
correction: Should be “includes”.
Chapter Page 31: Shouldn’t this be a first level
9
bullet? It doesn’t follow from the one above
it.
Chapter Page 38, Section I12: Suggest putting
9
"Notice of Medicare Non-Coverage" in
quotations.
Chapter Page 39, Section I.2: This should be changed
9
to Quality Improvement Organization.
Chapter
9
Chapter
9

Page 41, section I4, Formatting: The bullets
under if we say no to your fast appeal should
be sub-bullets.
Page 41, Section I.5: Should hospital
discharge be replaced with “termination,
suspension, or reduction of previously
authorized services:”?

Response

CMS agrees and has made this update.
CMS has made this update.
CMS has made this update.
CMS has made this update.
CMS has made this update.
CMS has made this update.
CMS has made this update.
CMS has made this update.
CMS has made this update.
CMS has made this update.
CMS declines to make this edit and will
leave the language as it currently stands.
CMS notes that this section is not about the
regular appeals process. Rather, it is about
the quick review the Independent Review

Chapter Comment

Response
Organization does when someone is
discharged from the hospital but the enrollee
believes that it is too soon.

Chapter
9
Chapter
9

Page 41, Section I.5: Under heading:
Formatting or content may be missing here.
Page 41, Section I.5: Should covered
inpatient hospital services be replaced with
“File Typeapplication/pdfFile TitleSummary of Comments and Responses for 60-day PRA Integrated Annual Notice of Change (ANOC) and Evidence of Coverage (EOC) ModelsSubjectPRA Integrated ANOC & EOC Models Comments & Responses SummaryAuthorCMS-MMCOFile Modified2023-01-17File Created2023-01-17