Best Practices for Submitting Your SNP Model of Care

Author: Linda Uwumarogie

Special Needs Plans (SNPs) are specialized Medicare plans that provide targeted care to specific groups of beneficiaries with specialized needs. Enrollment in these plans has nearly tripled in the past decade.¹ SNPs—including D-SNPs, C-SNPs, and I-SNPs—must annually submit a Model of Care (MOC) for review that provides a detailed description of an SNP’s care approach, focusing on steps to improve special needs plans, health outcomes, coordinate care, and effectively utilize community resources.

The MOC serves as a framework for plans to enhance care quality for Medicare beneficiaries with complex medical needs in a cost-effective manner. It addresses these needs by offering a comprehensive, member-centered approach that is tailored to individuals. Moreover, it promotes evidence-based practices, improves care coordination, and encourages member engagement.

If your organization is preparing for annual MOC submission, it’s crucial that your team accurately interprets regulatory requirements, prepares well in advance, undergoes training and education, and understands the operational aspects of running a SNP.

Need help designing and implementing a new SNP product? Read a free case study on navigating a successful MOC submission process and smooth D-SNP product implementation.

Enacting the Components of the SNP MOC
To ensure the success of a SNP MOC, it’s essential to focus on four key elements within the MOC. Take a closer look at each component to understand what’s contained within each.
MOC 1: SNP Target Population:
Identify the target population by considering their health, chronic conditions, functional limitations, social factors, and cultural background. Understanding the unique characteristics and needs of your most vulnerable members allows you to develop personalized care plans.

• MOC 1A: Overall SNP Population
• MOC 1B: Most Vulnerable Enrollees

MOC 2: Care Coordination:

Emphasize the coordination of care across different providers and settings. Establish a well-structured staffing approach, along with training and care transition protocols to ensure population needs and preferences are addressed effectively.

• MOC 2A: SNP Staff Structure
• MOC 2B: Health Risk Assessment
• MOC 2C: Face-to-Face Encounter
• MOC 2D: Individualized Care Plan (ICP)
• MOC 2E: Interdisciplinary Care Team (ICT)
• MOC 2F: Care Transition Protocols (CTP)

MOC 3: Provider Network:

Ongoing training and monitoring of the provider network are critical in meeting population needs and improving enrollee outcomes. Collaborate with the interdisciplinary care team and ensure specialized expertise within the network for success.

• MOC 3A: Specialized Expertise (CMS Regulation)
• MOC 3B: Clinical Practice Guidelines (CPG)/Care Transition Protocols (CTP)
• MOC 3C: Training for the Provider Network

MOC 4: Quality Measurement:

Focus on continuous quality improvement related to the overall MOC. Develop a quality performance improvement plan, set measurable goals and health outcomes, and evaluate member experiences of care to demonstrate your commitment to delivering high-quality service.

• MOC 4A: Quality Performance Improvement Plan
• MOC 4B: Measurable Goals and Health Outcomes for MOC
• MOC 4C: Measuring Patient Experience of Care (SNP Enrollee Satisfaction)
• MOC 4D: Ongoing Performance Improvement Evaluation of the MOC
• MOC 4E: Dissemination of SNP Quality Performance Related to the MOC

Preparing for the SNP Submission

At Clearlink, we understand the importance of meeting SNP MOC standards and differentiating your organization in a competitive marketplace, especially with the recent integrated care requirements out of CMS and states like California. In May 2022, CMS finalized a rule requiring Medicare-Medicaid plans (MMPs) to transition their MMP enrollees to integrated Medicare Advantage Dual-Eligible special needs plans (D-SNPs) by 2025.²

Here are some initial steps you can take to prepare for a successful SNP submission:

1. Invest in Tailored Interventions:
   Make the most of your work by investing in customized interventions like those offered by Clearlink, designed to help your organization enhance the quality of care provided to vulnerable populations.
2. Follow Regulatory Requirements:
   Accurately interpret and adhere to regulatory requirements to ensure a successful SNP submission. Stay updated on the latest federal and state guidelines for compliance throughout the process.
3. Dedicate Time and Resources:
   Allocate the necessary personnel and budget to effectively complete the SNP MOC preparation and submission process. In cases where resource shortages pose a challenge, Clearlink also offers co-sourcing solutions to help address these gaps.
4. Train and Educate your Team:
   Provide comprehensive training and education to any team members involved in the SNP MOC submission process. A well-informed and knowledgeable team will be better equipped to facilitate the smooth navigation of requirements.

By implementing best practices and leveraging available resources, your organization can develop and implement a high-quality SNP Model of Care. Demonstrating your commitment to delivering high-quality healthcare services to your members not only meets regulatory requirements but also sets you apart in the competitive healthcare marketplace—and Clearlink is here to support you through every step of the submission process.

Download your SNP MOC Submission Checklist here to get started!

Sources:

1. The Commonwealth Fund, “Taking Stock of Medicare Advantage: Special Needs Plans”
2. MACPAC, “Medicare-Medicaid Plan Demonstration Transition Updates and Monitoring”