The Medicare Rights Center (Medicare Rights) appreciates this opportunity to comment on the Bipartisan Policy Center’s white paper, “Policy Options for Integrating Care for Individuals with Both Medicare and Medicaid.” Medicare Rights is a national, nonprofit organization that works to ensure access to affordable health care for older adults and people with disabilities through counseling and advocacy, educational programs, and public policy initiatives. Each year, Medicare Rights provides services and resources to nearly three million people with Medicare, family caregivers, and professionals.

General comments

We are pleased with this set of policy options for integrating care for dually eligible individuals. On our national helpline, we have seen the serious issues that can arise when care is not fully integrated, especially when beneficiaries are forced to engage with disparate grievances and appeals processes. Too often, the provider, plan, or even state personnel do not understand both programs, what services intersect, and how to file timely appeals. We urge the full integration of grievance and appeals processes as well as the creation of robust participant ombudsman and transparency in appeals decisions records to ensure that people with Medicare and Medicaid are receiving care in a timely, fair, and affordable manner.