The Centers for Medicare and Medicaid Services (CMS) is proprosing an Exchange Program Integrity rule (CMS 9922-P), where a number of changes will reduce the number of individuals who are dually enrolled in Exchange plans and Medicare (as well as other forms of minimal essential coverage). While we are concerned about the number of beneficiaries who have inadvertently delayed Part B enrollment and stayed on Exchange plans, we are concerned about the proposed tactics in this rule to remove beneficiaries from Exchange plans. 

CMS' proposal to enable Exchanges to remove beneficiaries from Exchange plans if the beneficiaries are eligible for or enrolled in Medicare Part A would likely lead to harmful gaps in coverage for beneficiaries that have little support or understanding of their Medicare coverage options.

Read this January 8, 2019 comment letter NCOA submitted a to CMS on the proposed Exchange Program Integrity rule (CMS 9922-P).