Release of the Contract Year 2025 Medicare Advantage and Prescription Drug Proposed Rule 


View in browser | Distributed by Center for Medicaid and CHIP Services (CMCS)

We are writing to call state attention to the release of the Contract Year 2025 Medicare Advantage and Prescription Drug Proposed Rule (CMS-4205-P). We encourage states to review the entire proposed rule, but some proposals of particular interest to states are under the following headers:

  • Increasing the Percentage of Dually Eligible Managed Care Enrollees Who Receive Medicare and Medicaid Services from the Same Organization. Proposals would – 
    • Replace the current quarterly special enrollment period (SEP) with a one-time-per month SEP for dually eligible individuals and others enrolled in the Part D low-income subsidy program to elect a standalone PDP;
    • Create a new integrated care SEP to allow dually eligible individuals to elect an integrated D-SNP on a monthly basis;
    • Limit enrollment in certain D-SNPs to those individuals who are also enrolled in an affiliated Medicaid MCO; and
    • Limit the number of D-SNPs that organizations can offer in certain circumstances
  • Contracting Standards for Dual Eligible Special Needs Plan Look-Alikes, which would lower the current threshold for identifying D-SNP look-alikes
  • Expanding Permissible Data Use and Data Disclosure for MA Encounter Data, which would expedite state access to MA encounter data for care coordination for dually eligible individuals
  • For D-SNP PPOs, Limiting Out-of-Network Cost Sharing, which would reduce state liability for Medicare cost sharing in certain instances
  • Update to the Multi-Language Insert Regulation

The proposed rule also includes three comment solicitations that may be of particular interest to states:

  • Medicare Plan Finder and Information on Certain Integrated D-SNPs
  • State Enrollment Vendors and Enrollment in Integrated D-SNPs
  • Use of MA Encounter Data to Support Required Medicaid Quality Reporting

Please review the full proposed rule for more information. The press release and fact sheet can be found at: Press Release and Fact Sheet. We encourage states to review and comment by the deadline, January 5, 2024.