Should Off-cycle MOC Submission Be a Priority, RIGHT NOW?

December 1, 2024, signals closure of the 2024 the National Committee for Quality Assurance (NCQA) Model of Care (MOC) Off-Cycle submission window, but there is still time to update if you act fast and maximize the benefit of the off-cycle submission.   For Dual-Eligible Special Needs Plans (D-SNPs) and Institutional Special Needs Plans (I-SNPs) desiring to make substantive changes to operational processes while administering a previously approved MOC, preparation for off-cycle submission should also be today’s priority (Chronic Condition Special Needs Plans (C-SNPs) or other SNPs that will be administering a newly approved MOC in 2025 are not eligible to submit off-cycle revisions). While December 1,^, 2024, signals closure of the 2024 NCQA MOC Off-Cycle submission window, significant review and pre- work must be completed to maximize the benefit of the off-cycle submission.

BluePeak’s support of SNP Sponsors in 2024 program audits provided us the unique opportunity of identifying trends where multiple clients were subject to the same finding of non-compliance, with similar root causes. For example, for the findings related to not developing ICPs and/or not reviewing and/or revising ICPs consistent with the MOC, BluePeak experienced high-performing teams being unexpectedly cited for non-compliance. The commonality between the teams was a lack of understanding of the requirements for the Sponsor’s approved MOC specific to:

• Timeframes for reviewing/developing/updating/editing care plans based on stratification
• Outreach frequency, based on enrollee stratification
• Review and revision of ICP based on a change in status
• Timeliness of implementing transition protocols
• Inclusion of long- and short-term goals

Publishing specific and/or aggressive goals in a MOC, when such goals are not required to obtained a sufficient score for three-year approval, puts the SNP at an increased risk for findings of non-compliance during a program audit. A MOC should provide the framework that defines how health services are delivered, at minimum. Now is the time to review previously approved MOCs that will carry over into 2025 and submit off-cycle revisions to mitigate any risk identified during that review. Sponsors must keep in mind that substantial changes to target populations, care coordination policies and procedures, and benefit offerings related to SNP operations, to name a few, cannot be implemented until NCQA and the Centers for Medicare and Medicaid Services (CMS) approves the change through the off-cycle process.

BluePeak has experience proactively identifying risk for non-compliance and opportunities to mitigate that risk through off-cycle revisions to the MOC. BluePeak also has experience identifying opportunities for change to operational processes after identification of non-compliance. This is especially important when the approved MOC requirements would likely prevent validation of the corrective action (i.e., Sponsor is likely unable to ensue 100% compliance in a validation audit).

BluePeak wants to partner with SNPs to enter 2025 well poised for audit success, but time is of the essence! The window for submitting MOC revisions is opened through December 1, but NCQA only downloads submissions on the 15^th of each month. Barring any issues that require cure, the results of the review are then uploaded on the 15^th of the following month. This means a submission on or before November 14^th is needed to allow organizational changes to take effect on or before January 1, 2025.