NAELA and 32 Other Organizations to CMS: Protect the Vulnerable Elderly

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Advocacy groups call for increasing transparency, limiting the size of dual eligible demonstrations, and assuring that states are ready to manage new care models.

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NAELA is committed to promoting the public policy positions that will best serve today’s elderly and people with disabilities.

The National Academy of Elder Law Attorneys (NAELA) and 32 advocacy groups sent Melanie Bella, Director of the Medicare-Medicaid Coordination Office, recommendations and concerns regarding the current dual eligible demonstrations process.    

“There are currently seven million elderly low-income Americans who qualify for both Medicare and Medicaid, known as dual eligibles. These dual eligibles are among the nation’s most vulnerable population, yet many members of Congress have focused on cutting costs for these low-income elderly. NAELA is committed to promoting the public policy positions that will best serve today’s elderly and people with disabilities,” said NAELA President Gregory French, CELA, CAP. Fifteen states are currently developing demonstrations for the Centers for Medicare and Medicaid Services (CMS) on how to restructure health care for dual eligibles.    

In response to CMS’s request for concerns and comments to these demonstrations, NAELA and 32 other organizations submitted a report urging CMS to ensure that cost-saving techniques do not overshadow the need to provide quality health care to an already vulnerable elderly population.    

NAELA is urging CMS to:

  • Make this process as transparent as possible and include stakeholder input by providing the Memorandums of Understanding to the public. Making the Memorandums public will ensure that the elderly will remain protected and providers will be held accountable.    
  • Decrease its demonstration size to 1 million dual eligibles. Monitoring quality and delivery of care in a large system is very difficult. Advocacy groups do not believe that good person-centered integrated care can be provided this rapidly and as a result, elderly Americans will not receive the innovative integrated care originally desired.
  • Verify that integrated care entities have the experience and expertise to care for the complex needs of aging Americans. CMS must ensure that plans have adequate standards for services required by the elderly, such as in-home and community services.

You can read more of NAELA’s concerns and recommendations regarding dual eligible reform on the NAELA website.

Members of the National Academy of Elder Law Attorneys (NAELA) are attorneys who are experienced and trained in working with the legal problems of aging Americans and individuals of all ages with disabilities. Established in 1987, NAELA is a non-profit association that assists lawyers, bar organizations and others. The mission of NAELA is to establish NAELA members as the premier providers of legal advocacy, guidance and services to enhance the lives of people with special needs and people as they age. NAELA currently has members across the United States, Canada, Australia and the United Kingdom. For more information, visit

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Abby Matienzo, Communications Specialist
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