UCare Comments

August 29, 2012

CMS, Office of Strategic Operations and Regulatory Affairs
Division of Regulations Development
Attention: Document Identifier CMS-10237, Room C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850
Submitted electronically to http://www.regulations.gov
UCare CMS contract Numbers: H2456, H2459 and H4270

Dear Sir or Madam:
In response to the Comment Request regarding the Part C Medicare Advantage and 1876 Cost
Plan Expansion Application (CMS-10237) (OCN 0938-0935), UCare submits the comments
outlined in the following pages.
UCare is an independent, nonprofit health plan serving nearly 100,000 members of our Medicare
Advantage plans in Minnesota and western Wisconsin. UCare for Seniors, our Medicare
Advantage plan, earned 4.5 stars in the Medicare Star Ratings. In 2010, our members rated our
plan as an 8.8 for Overall Rating of Health Plans. This 2011 Consumer Assessment of
Healthcare Providers and Systems (CAHPS) score is higher than the national and Minnesota
averages. In addition to our individual and employer group Medicare Advantage business,
UCare is a leader in Minnesota with our integrated dual eligible Special Needs Plan (SNP). We
have served this population for many years in our MSHO plan.
Thank you for the opportunity to submit comments.
Sincerely,

Michelle Larson
Michelle Larson
Federal Government Relations Specialist

500 Stinson Blvd. NE Minneapolis MN 55413-2615
P.O. Box 52 Minneapolis MN 55440-0052
612-676-6500
1-866-457-7144
TTY: 1-800-688-2534
Fax: 612-676-6501
www.ucare.org

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 For Attestation under section 3.10.A, item #15, please verify what is meant by “at least
one of the past two Medicare Advantage application review cycles.” Is this the time
period for the previous two calendar years when a plan may have received an automatic
renewal? Or is this the previous two times that a plan has completed an application,
either as a service area expansion or a new application regardless of the time between
such applications?
 For section 3.28, tiering of medical benefits, we suggest adding a column for not
applicable. If a plan does not tier benefits, would they answer the attestation (“equal
access to the various tiers proposed”) as yes or no if no tiers are proposed? A not
applicable option would be more accurate.
 For section 4.13, we suggest including instructions that this is optional if tiering of
benefits is not offered.
 Appendix I SNP proposal, Section 6, D-SNP State Medicaid Agency(ies) Contract(s),
questions 2 and 8 are duplicative.

500 Stinson Blvd. NE Minneapolis MN 55413-2615
P.O. Box 52 Minneapolis MN 55440-0052
612-676-6500
1-866-457-7144
TTY: 1-800-688-2534
Fax: 612-676-6501
www.ucare.org

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500 Stinson Blvd. NE Minneapolis MN 55413-2615
P.O. Box 52 Minneapolis MN 55440-0052
612-676-6500
1-866-457-7144
TTY: 1-800-688-2534
Fax: 612-676-6501
www.ucare.org

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