1. CMS Proposed Changes to SNP Model of Care Requirements
Valerie Wilbur
Co-Chair, The SNP Alliance and
Vice President, National Health Policy Group

2. CMS Proposed Changes to SNP Model of Care
Reduces MOC attestations from 253 attestations crossing 9 domains (2014) to 11 attestations crossing 2 domains (MOC submission and HRA).
Reorganizes MOC domains from 11 to 4, but maintains current elements and adds some new ones.
Creates purpose statements for each domain.
Increases and formalizes requirements for SNP population and ICTs in SNP application.
Establishes more prescriptive relationship among HRA, ICT, ICP.
Expands focus on health disparities.
Increases obligation of SNP management for SNP oversight.

3. SNP Alliance Perspectives
Reduction of SNP attestations is consistent with MOC approval requirements.
Greater specificity on Population and MOC helps document SNP/MA differences.
Sound logic to restructuring of domains.
Improves alignment with S&P in some areas.
Disparities focus recognizes SES impact on SNP enrollees and that plans need to address.
Clarifies CMS expectations about MOC, but increases reporting burden.
Could move toward complex care model for all SNPs; flexibility critical to meet varied needs and effectively allocate resources to heterogeneous SNP enrollees.

4. MOC: Intense Focus on Detail, Paper Compliance, Granular Process Requirements
More process requirements vs. outcomes.
Very detailed description of SNP population.
Paper driven transition care process vs. outcome orientation.
Extremely detailed structure for HRA, ICP, ICT.
ICT composition driven by HRA, ICP.
Prescriptive relationship among HRA, ICP, ICT.
Training requirements – all employees, contractors, network and non-par. Providers.
Assumes significant control over provider networks.

5. MOC: Complex Care Management Focus
Beneficiary participation in care management.
Face-to-Face ICT interactions (for enrollees and providers).
Scope and Intensity of ICP, link to HRA
Frequency of reassessments/ICP adjustments (continuous)
Exchange of enrollee info across ICT, providers, enrollees, stakeholders (regular)
Uniform management of all transitions (any)

6. MOC: Duplication SNP population and vulnerable subset
Provider network and standard MA network requirements
Staffing roles/responsibilities across 5 elements of care coordination domain
Quality domain elements

7. MOC: Implementation & Issues
Implementation & Policy Issues:
Release date for final MA app
Training date for new MOC rules
Grandfathering of MOCs
Existing approval, no changes for 2015
Existing approval, SAE for 2015
Marketing MOC score/approval period, per new HOS guidance

8. For Further Conversation
Valerie Wilbur, Vice President, NHPG and Co-chair, SNP Alliance
Phone:
National Health Policy Group
750 9th Street, NW
Suite 600
Washington DC 20001