Changes Are Ahead for C-SNPs and D-SNPs

The Centers for Medicare & Medicaid Services (CMS) announced yesterday that beginning in 2020, all current Chronic Condition Special Needs Plans (C-SNPs) must submit their Model of Care (MOC) to CMS annually for evaluation and approval by the National Committee for Quality Assurance (NCQA). The approval will last for one year, and plans must continue to resubmit their C-SNP MOC annually for review and approval. The annual MOC submission and approval does not apply to Dual Eligible Special Needs Plans (D-SNPs) and Institutional Special Needs Plan (I-SNPs), at least not yet.

CMS also announced they will implement a minimum scoring benchmark system for each C-SNP MOC element. Plans will be approved only if they achieve the minimum scoring benchmark for each element. CMS will also propose rulemaking to implement the minimum scoring benchmark for D-SNPs and I-SNPs in 2021.

These updates represent significant changes to both the C-SNP MOC submission and scoring processes that will impact all current and new C-SNPs going forward. The scoring changes will also have a significant impact on D-SNPs and I-SNPs if CMS moves ahead with rulemaking to adopt the scoring benchmark across all SNP MOCs in 2021.

There is no time like the present to start identifying process changes that need to be made to support the upcoming requirements. If your organization would like to discuss how Gorman Health Group can assist with your preparations, please contact us at




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Jane Scott
Jane Scott

Jane Scott is Senior Vice President of Population Health Management and Clinical Innovations at Gorman Health Group (GHG). In this role, she is responsible for leading GHG’s Clinical Innovations practice area. Jane brings GHG clients 37 years of experience in healthcare as one of the industry leaders on the topics of the Centers for Medicare & Medicaid Services (CMS) Special Needs Plans (SNPs), development and implementation of Models of Care (MOCs), as well as the Star Ratings Quality Bonus Payment Program. Her experience expands to the areas of quality improvement (QI), utilization and medical management, claims operations, and provider/associate education.

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