policy
ACAP Submits Policy Recommendations on D-SNP Sustainability
On September 3, ACAP submitted policy recommendations for CMS’s consideration on D-SNP sustainability for the upcoming CY 2026 regulatory process.
The letter shares ACAP’s appreciation for CMS’s work to improve care for dually eligible beneficiaries, particularly efforts to improve Medicare and Medicaid integration through D-SNPs.
It also includes the following policy recommendations:
- Recommendation 1: Introduce Additional Part D Risk-Mitigation Strategies for MA-PDs in CY 26
- Recommendation 2: Revise the Tukey Outlier Deletion Methodology
- Recommendation 3: Publish Plan Impacts Separately for D-SNPs and Integrated D-SNPs
- Recommendation 4: Continue Allowing D-SNPs to Submit Diagnostic Codes Obtained
Through HRAs and Chart Reviews
Read the letter in full, including expanded comments, via the sidebar on the right.