Off-Cycle MOC Submissions – Is It Time?

Remember, your plan must be operating from an approved Model of Care (MOC).

The off-cycle submission process allows for substantial changes such as fundamental organizational changes essential to the MOC process and functions; for example, changes to an organization’s MOC narrative that occur between approval periods (e.g., year 2 of a three-year approval) and have not expired.

The Centers for Medicare & Medicaid Services (CMS) created off-cycle review in an effort to establish a process for Special Needs Plans (SNPs) to provide revisions to their approved MOCs. This allows CMS to adequately monitor the approved MOCs to ensure high-quality care is delivered to the enrollees. If you answer “yes” to any or a combination of the following, your plan needs to consider an off-cycle MOC submission:

  • Have there been target population changes regarding medical conditions or services (e.g., changes to the most vulnerable population and services)?
  • Are there changes to structure such as policies and procedures relevant to Care Coordination Elements?
  • Are there new benefit inclusions or exclusions?
  • Has there been a change in legal entity, parent organization, and oversight (e.g., re-organization, merger)?

If you do not submit for an “off-cycle” review, SNPs must operate under the originally approved MOC and continue through the remaining approval period, subsequently impacting the plan’s performance in a CMS SNP MOC audit.

Gorman Health Group has a clinical team ready to assist you at any level of need: gap analysis, revision of MOC, development and implementation of new processes, and more!



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