Is your Special Needs Plan (SNP) due for a 2025 Model of Care (MOC) submission?
With a due date of February 2024, we encourage you to not wait to review your MOC and start planning NOW! Plans that wait until late in the year to update or change their MOC may find it difficult to complete all the required changes for timely and successful submission to National Committee for Quality Assurance (NCQA).
Below is a sample of a few CMS required changes that will impact your SNP Care Coordination program and MOC submission:
- Effective 2023; D-SNP plans offering one or more dual eligible special needs plans (D-SNPs) in a state must establish and maintain one or more enrollee advisory committees to solicit direct input on enrollee experiences. CMS has said this will be added to the protocols, and while they have not yet been updated, plans must comply as this has been finalized in policy and codified in regulations under 42CFR 422.107(f).
- Requirements for governing SNP enrollee care management have been updated as well from the 2022 Final Rule which have been further clarified in the 2023 Final Rule.
- The interdisciplinary care team (ICT) must be appropriate for the needs of each enrollee.
- A face-to-face encounter must occur at least annually.
- Integrated Care Program (ICP) includes needs from the Health Risk Assessment (HRA)
- Plan performance in the MOC must outline whether goals were met or not met and what actions are being taken.
- Minimum benchmarks for scoring the MOC have been updated to require that each element attain a score of 50% regardless of the overall score for the MOC.
- While HRA submission is not required under your MOC submission, in 2025 CMS requires that all SNPs (C-SNPs, D–SNPs, and I-SNPs) include one or more questions from a list of screening instruments specified in sub-regulatory guidance on the topics of housing stability, food security, and access to transportation as part of their HRAs. CMS has established SNPs choose questions from the CMS approved tools on these topics that are most relevant to their enrollee populations to include on their assessments. Plans should update their HRA if not already done to include these questions chosen from approved CMS tool.
Sponsors who submitted MOC last year have already included the above, but if you are just renewing this year, these cannot be missed! BluePeak is available to assist with review and editing and writing your MOC before time runs out! Did you miss the RISE SNP Leadership Conference in New York last month? Contact us to review our presentation on “Lessons Learned from Recent CMS Audits” featuring Humana.
