Laura Zwolinski: Good afternoon, everyone. Laura Zwolinski: We're looking forward to our technical assistance call this afternoon. We'll go ahead and get started in a minute or two, once we see the attendee count start to stabilize as folks join. Thank you. Laura Zwolinski: Give it a… A little more time, and then we will go ahead and get started. Laura Zwolinski: Okay, it looks like the number of attendees is now somewhat steady, so we can move into our session for the day. Laura Zwolinski: Good afternoon, and welcome to the first SNP Approval Model of Care pre-submission Technical Assistance call for Contract Year 2027. Laura Zwolinski: We look forward to sharing key information with you for Contract Year 2027, and to hearing your questions today. Laura Zwolinski: Next slide, please. Laura Zwolinski: This slide includes some of the NCQA team members supporting the SNP model of care review and approval effort. Laura Zwolinski: My name is Laura Zielinski, I am a director in NCQA's Quality Solutions Group, and I currently serve as NCQA's Task Lead for SNP Model of Care Review Activities. Laura Zwolinski: I'd also like to introduce Sri Patel, NCA's Content Analyst, Madeline Vancott, NCQA's Lead Analyst, and Alan Hoffman, NCQA's Quality Solutions Group Vice President, who has responsibility for the overall direction of NCQA's work on the SNP approval process. Laura Zwolinski: Next slide. Laura Zwolinski: And I'll now pass things over to our colleague at the Centers for Medicare and Medicaid Services to introduce themselves. Daniel Lehman: Hello, thanks for joining us again this year. My name is Daniel Lehman. I'm in the Center for Medicare, Medicare Drug and Health Plan Contract Administration Group in the Division of Policy Analysis and Planning. Daniel Lehman: We will be joined later by my colleague, Emily Moore. We work on SNP policy, and like I said, we are glad to have you here today. Daniel Lehman: Laura and team, back to you. Laura Zwolinski: Thank you, Dan. And so, on behalf of NCQ and CMAS, we do welcome you to our first of two SNP Model of Care pre-submission technical assistance calls, and we thank you in advance for your time, participation, and attention today. Laura Zwolinski: Next slide. Laura Zwolinski: In terms of today's call agenda, we'll cover a few housekeeping items. Laura Zwolinski: Review the SNP submission timeline, as well as important submission guidance. Laura Zwolinski: Present some key updates and reminders for contract year 2027. Laura Zwolinski: And then we will go ahead and open it up for questions. Laura Zwolinski: Next slide, please. Laura Zwolinski: In terms of Zoom housekeeping items, we have muted everyone's lines to reduce audio feedback. Laura Zwolinski: During the designated Q&A portion of the call, we'll allow you to unmute yourself to ask questions live. Laura Zwolinski: Please feel free to post questions via the Q&A feature located in the menu bar at the bottom of your Zoom screen at any time during the call. Laura Zwolinski: Depending on your question, we may answer it via the Q&A feature, or we may respond to it live during the Q&A portion of the call. Laura Zwolinski: Please note that the chat function has been disabled for attendees, so all written questions will need to be submitted via the Q&A feature. Laura Zwolinski: Lastly, we will have dedicated time following the slide presentation for attendees to ask questions live. Laura Zwolinski: If you'd like to ask a question during this time, please use the raise hand button in Zoom. We'll then call you by name and enable you to unmute yourself to ask your question. Laura Zwolinski: After asking a question, please be sure to mute yourself. Laura Zwolinski: Next slide. Laura Zwolinski: In terms of technical assistance, you can access all training recordings, slides, and the contract year, or CY, 2027 Model of Care Matrix and Scoring Guidelines on the NCQA SNP Approval website. Laura Zwolinski: There are four separate trainings this year, one for each of the four MOC standards. Laura Zwolinski: You can also access login information for upcoming TA calls and the recordings from these calls on this site. Laura Zwolinski: For inquiries related to MOC requirements or regulation questions, please contact CMS at the address included in the middle column of this slide. Laura Zwolinski: Please submit SNP application inquiries via the CMS SNP mailbox noted in the right column of this slide. Laura Zwolinski: And lastly, we encourage you to review CY2027 training materials and guidance prior to submitting inquiries. Laura Zwolinski: Next slide. Laura Zwolinski: Please note that the SNP model of care approval timeline has shifted for CY2027 compared to prior years. Laura Zwolinski: At this point, the CY2027 Model of Care Matrix, scoring guidelines, and all training recordings have been made available. Laura Zwolinski: Today is the first of two pre-submission technical assistance calls. The second will be held on Thursday, April 16th. Laura Zwolinski: Plants can start uploading CY 2027 Model of Care submissions starting on May 19th, and all submissions are due in HPMS no later than 8 p.m. Eastern Standard Time on Friday, May 29th, 2026. Laura Zwolinski: This timeline change aligns the CMS MOC submission process with the Medicare Advantage statutory bid submission deadline and state Medicaid agency contracting processes. Laura Zwolinski: Beginning this year and moving forward, the MOC submission deadline will move to the Friday before the first Monday in June, which is the day final bids are due to CMS. Laura Zwolinski: In 2026, final bids are due on Monday, June 1st. Laura Zwolinski: Scores will be entered into HPMS by the end of July. Laura Zwolinski: On Monday, August 3rd, CMS will distribute Notice of Intent to Deny Letters, or NOIDs, to plans that score less than 50% on any one or more elements. Laura Zwolinski: Or that score less than 70% overall. Laura Zwolinski: These SNPs are required to address deficiencies during a designated period called the cure. Laura Zwolinski: A TA call with instructions for how to cure documentation will be held on Tuesday, August 4th. Laura Zwolinski: All CURE submissions are due in HPMS by 8pm Eastern Standard Time on Thursday, August 13th. Laura Zwolinski: Following the CURE review period, CMS will issue approvals and denials on September 1st. Laura Zwolinski: Next slide. Laura Zwolinski: We'd like to call out some key points to keep in mind as you prepare and submit your submissions this May. Laura Zwolinski: Again, all submissions must be uploaded in HPMS by 8pm Eastern Standard Time on Friday, May 29th. Laura Zwolinski: Please upload only two documents to HPMS, the MOC narrative itself, and the associated matrix, as these are the only documents NCQA downloads and reviews. We do not download or review any other documents or attachments. Laura Zwolinski: Given this, please verify that all information or documents necessary to complete our review are embedded directly under the appropriate location in the model of care, or included as appendices at the end of the document. Laura Zwolinski: We encourage you to use the file naming convention shown on this slide for your documents when you submit. Laura Zwolinski: To support consistency across reviews, we ask that you specify in the matrix all corporate-affiliated H numbers that share a similar model of care. Laura Zwolinski: We strongly advise SNPs to thoroughly consider your model of care. Laura Zwolinski: Each submission year is an opportunity to think through and improve processes. Laura Zwolinski: SNP submitting renewal models of care should include any planned substantive changes in the annual submission. Laura Zwolinski: The expectation is for SNPs to submit a new model of care each renewal period to capture process updates and changes. Laura Zwolinski: In terms of the format and structure of the model of care. Laura Zwolinski: Please ensure that responses are provided in the same order specified in the CY2027 scoring guidelines, and that they capture all current requirements. Laura Zwolinski: This supports a more efficient review process and aligns your model of care with the most current guidance. And we thank you in advance for your cooperation on this. Laura Zwolinski: Lastly, make sure that you do not include any protected health information or personally identifiable information within the model of care. Laura Zwolinski: Next slide, please. Laura Zwolinski: We're now going to turn our attention to a review of key updates and reminders for CY2027. Laura Zwolinski: Next slide. Laura Zwolinski: In terms of high-level changes made for CY2027, we want to emphasize that substantive changes have been made to element and factor requirements this year to reflect revisions made to the MOC matrix, which CMS released earlier this year. Laura Zwolinski: In addition, the CY2027 scoring guidelines were updated to align with the revised model of care matrix. Laura Zwolinski: To ensure that you understand these revisions and the corresponding changes you'll need to address in your model of care documentation. Laura Zwolinski: We strongly encourage you to review this year's Model of Care Matrix and scoring guidelines thoroughly, as well as to listen carefully to all four training recordings. Laura Zwolinski: Lastly, please ensure that the structure and order of elements and factors in your model of care aligns with the order included in the CY2027 scoring guidelines. Laura Zwolinski: Next slide. Laura Zwolinski: We're now going to review some of the key changes made at the element and factor levels for CY2027. Laura Zwolinski: Please note that, given the volume of changes made this year, this is not a comprehensive or exhaustive list of all revisions made. Laura Zwolinski: or a list of all requirements. However, it does capture key overall changes. Laura Zwolinski: Please ensure that you review the model of care matrix and scoring guidelines, and listen to all training recordings to capture, understand, and address all changes made for this year. Laura Zwolinski: We'll begin with MOC1A, the description of the overall and most vulnerable enrollees. Laura Zwolinski: This element underwent substantive content and factor order changes this year. Laura Zwolinski: Primarily, the element was expanded to focus not only on the general population, as it did in the past, but also on the most vulnerable population. Laura Zwolinski: Prior Factor 1, which required information on eligibility verification and tracking, was deleted and replaced with New Factor 1. Laura Zwolinski: This new factor requires that SNPs identify their SNP type, that is, whether it is a CSNP, DSNP, or ISNP, Laura Zwolinski: the SNP detail, for example, chronic lung disorder, if you are a CSNP, or for an ISNP, Laura Zwolinski: An example is Hybrid institutional. Laura Zwolinski: DSNPs must also specify the intended integration level, for example, fully integrated, highly integrated, or coordination only. Laura Zwolinski: And must also describe the eligibility categories and criteria. Laura Zwolinski: For example, QMB only, QMB+, SLMB only, SLMB+, etc. Laura Zwolinski: Lastly, all SNPs must specify whether the submission is an initial, a renewal, or an off-cycle submission. Laura Zwolinski: Next slide. Laura Zwolinski: Please note that the order of factors for 2 through 4 has shifted, and all of these factors now require information for both the general and the most vulnerable populations. Laura Zwolinski: For Factor II, SNPs must provide demographic data and details for both populations. Laura Zwolinski: Please be sure not to provide the same data across these populations. Laura Zwolinski: For Factor III, SNPs must describe the health status of both populations, including data on major diseases and comorbidities, as well as the social, cognitive, environmental, and living condition factors. Laura Zwolinski: For Factor 4, SNPs must describe conditions and other health factors that impact each population. Laura Zwolinski: For example, health literacy, poor socioeconomic status, housing, food, transportation insecurities, etc. And also describe actions taken to address these needs. Laura Zwolinski: For all of these factors, be sure to differentiate between the general and most vulnerable populations. Laura Zwolinski: In addition, SNPs renewing their contracts after year two of operations must provide their own historical data instead of other national, local, or proxy data. Laura Zwolinski: Renewal plans are expected to provide their own membership data. However, if you are a renewing plan that just began operations, or has not been operational for 2 years yet. Laura Zwolinski: You may include proxy data, however, in this case, you do need to indicate that this is the reason for including proxy data, and specify how the data approximates the intended target populations. Laura Zwolinski: Lastly, do not use membership data that is from prior to 2022, and be sure to specify years and data sources. Laura Zwolinski: Next slide, please. Laura Zwolinski: This is an example of how plans can address Factor 2, which requires the provision of demographic data for the general and most vulnerable populations. Laura Zwolinski: Plans most commonly use a table to display the required demographic information, identifying each service area in the target population. For instance, county or state. Laura Zwolinski: And including a demographic breakdown of age, sex, ethnicity, language spoken, and education for each. Laura Zwolinski: This is the level of detail we are looking for in terms of demographic data. Laura Zwolinski: Please ensure that demographic details for both the general and the most vulnerable populations are included. Laura Zwolinski: That all information is specific to the populations served, and that it is provided for all service areas. Laura Zwolinski: Some plans opt to include a narrative of demographic information rather than a table. Laura Zwolinski: This approach is also acceptable. However, if using this format, the same level of detail is expected. Laura Zwolinski: NCQA and CMS are not prescriptive on how SNPs choose to share this data and information, as long as all specified components are addressed. Laura Zwolinski: Next slide. Laura Zwolinski: MOC 1B, Services for the most vulnerable enrollees, also had substantive contact and factor order changes this year. Laura Zwolinski: Previously, this element focused on a description of the most vulnerable population. Laura Zwolinski: This year, it has been revised to focus on the identification of the most vulnerable enrollees, the services provided to these enrollees, and the partnerships established to support them. Laura Zwolinski: As a note, two factors, were newly included this year, which we'll review on the next slide. Laura Zwolinski: For Factor 1, please be sure to provide a detailed and specific list of the inclusion criteria used to determine the most vulnerable population, in addition to a description of the internal processes used for identification. Laura Zwolinski: We are emphasizing that these criteria be specific, as this is information that plans have sometimes omitted in the past. Laura Zwolinski: Next slide, please. Laura Zwolinski: Factor 2 is new this year, and focuses on the benefits tailored to, and the care management practices employed for the most vulnerable enrollees. Laura Zwolinski: These must be above and beyond the services and practices provided to the general population. Laura Zwolinski: Please also describe how the SNP will meet the needs of these vulnerable enrollees across the continuum of care. Laura Zwolinski: Factor 3 requires a description of established partnerships with community organizations that provide, facilitate, or assist in identifying resources for the most vulnerable enrollees and or their caregivers. Laura Zwolinski: Plans must describe how the SNP collaborates with its partners to facilitate access to community services, deliver needed services, and maintain continuity of services for the most vulnerable and or caregivers, as well as how they support and maintain these partnerships. Laura Zwolinski: This response requires a list of partnerships and available services specific to the SNP service area. Laura Zwolinski: Please note that while last year's plans could earn credit, if they described the system used to house, research, identify, and access these resources, this approach no longer suffices to earn credit this year. Plans must include a list of current partnerships for CY2027. Laura Zwolinski: Lastly, Factor 4 is also new this year. It requires the plan to explain any challenges associated with establishing community organization partnerships that impact the ability to connect enrollees to specific services. As part of this response, SNPs must describe potential mitigation strategies and solutions. Laura Zwolinski: Of note, MOC 1A and 1B were some of the most frequently failed elements last year. So that is, not meeting these elements was a common reason that plans were required to cure. So given this, we wanted to emphasize the need for plans to follow the guidance provided for these elements. Laura Zwolinski: And with that, I will hand things over to my colleague, Sri, to review the key changes for MOC Standards 2 and 3. Next slide. Shree Patel: Thank you, Laura, I appreciate that. For MOC 2A, which is about SNP's staff structure, prior Factor 1, which required information on administrative staff roles and responsibilities, was deleted. Shree Patel: This shifted all other factors in the element up by 1 and reduced the number of factors in this element from 7 to 6. For Factor 3, we'd like to call out that new for this year, in addition to describing contingency plans to ensure ongoing continuity of critical staff functions. Shree Patel: Plans are also required to describe their disaster preparedness and recovery plans in the event of an emergency. Shree Patel: We also have some reminders for Factor 4. Renewal submissions must include a sample of specific and substantive training slides or materials. Do not submit title and or overview slides in the absence of specific training content. Shree Patel: Initial submissions must provide a sample of training slides if available. Otherwise, they should provide a detailed narrative description of training content. Shree Patel: Do not provide general information, such as a table of contents or bulleted lists of topics without substantive details. Next slide, please. Shree Patel: For MOC2B, the Health Risk Assessment, or HRA, factors were reordered to align more closely with the order of clinical operations. Shree Patel: Factor 1 requires that plans describe how they conduct the initial HRA and annual reassessment, and how the HRA assesses the medical, functional, cognitive, psychosocial, and mental health needs of each SNP enrollee. Please describe the administration process completely, addressing the who. Shree Patel: what, where, when, and how, and the methodology used to administer the HRA. Shree Patel: This year, a number of new requirements were specified, and must be addressed in order to earn credit for Factor I. Shree Patel: First, plans must summarize and describe the HRA tool or tools that they are using. Second, SNPs must specify the timing of the initial HRA and annual reassessments, which must align with the regulation. Shree Patel: That is, within 90 days of effective enrollment date for new enrollees and annually for existing members. Most plans are already providing this information. However, please be sure to include this if you are not already. Shree Patel: Third, SNFs must identify the qualified personnel who conduct the initial and annual HRAs, specifying their applicable licensure. Shree Patel: Plans must also detail the process used to attempt to reach enrollees to complete the HRA. This includes specifying the method used to contact enrollees, and how many attempts are made, and must align with the current regulations. Shree Patel: We understand that you will not be able to reach everyone, but SNPs need to clearly delineate the process taken to attempt to reach all enrollees, to complete an HRA, and the process for documenting refusals after outreach attempts have been exhausted. Shree Patel: The last new change is that plans must describe how they address challenges associated with enrollees who decline to participate in HRA completion or are unable to be reached. Shree Patel: As in prior years, plans must continue to detail how they use the HRA to reassess enrollees after the completion of the initial assessment, and there must be a provision to reassess enrollees if warranted by a health status change or care transition. Shree Patel: Next slide, please. Shree Patel: For Factor 2, SNPs must explain the detailed process used to review, analyze, and stratify HRA results. New this year, plans must describe each risk stratification tier, as well as provide the inclusion criteria and acuity level for each tier to earn credit. Shree Patel: In addition, the response must be… must describe how the SNP uses stratified results to improve the care coordination process. Shree Patel: Lastly, for Factor 3, as a reminder, please be sure to indicate how your SNP ensures that HRA results are included and addressed in the Individualized Care Plan, or ICP. Shree Patel: Next slide, please. Shree Patel: For MOC2C, the face-to-face encounter. Shree Patel: Prior Factor 5, which was about addressing health concerns, and 6, which was about care coordination activities, were combined into new Factor 5, reducing the number of total factors in this element from 6 to 5. Shree Patel: Factor 3 requires the SNPs to describe how it will verify through data collection that enrollees have participated in a qualifying face-to-face encounter. Shree Patel: As in the past, please detail this verification process, and speak to reporting, tracking, and responsible staff. Shree Patel: In addition, for CY2027, SNPs also need to describe any follow-up communications with the enrollee or caregiver during the face-to-face encounter verification process. Shree Patel: Lastly, Factor 5 now requires that SNPs describe how they ensure that appropriate follow-up referrals and scheduling for needed care and services are completed following the face-to-face encounter. Next slide. Shree Patel: For MOC2D, which is about the ICP, prior factors 2 and 3 were combined, reducing the number of factors from 5 to 4. Shree Patel: Please note that ICPs must be developed for each enrollee. They must be person-centric, and are not limited to enrollees in care management programs, or those stratified as medium or high risk. Shree Patel: For Factor 2, SNPs must describe how they develop an ICP for each enrollee to deliver appropriate care. Shree Patel: SNPs must describe the ICP development process and detail how the results of the initial HRA and annual reassessment are included in the ICP. The MOC must also include a description of the frequency at which SNP personnel review the Shree Patel: update, and or modify the ICP based on the evaluation of enrollee goals, as prioritized by the enrollee. Changes in healthcare needs. Shree Patel: or status, or the availability of more recent HRA information. Shree Patel: There are a few new requirements specified for this year. Shree Patel: First, SNPs must specify the timing of the ICP development, which must comply with the regulations. That is, within 90 days of conducting the initial HRA, or 90 days after, effective date of enrollment, whichever is later. Shree Patel: SNPs must also identify the personnel responsible for developing the ICP, including roles and functions, professional requirements, and credentials. Shree Patel: In addition, SNPs must include information on how the enrollee and or their caregivers are involved and participate in the ICP development process. Shree Patel: Also newly specified for this year, the plan must describe how the SNP addresses challenges Shree Patel: associated with enrollees who declined to participate in the ICP process, or those who are unable to be reached, and how it documents the attempts to contact the enrollees, or the enrollee's refusal to participate. Shree Patel: Lastly, we want to draw your attention to the new DSNP-only requirement for this factor. Shree Patel: This component of Factor II only applies to DSNPs, and requires that they describe how the ICP is used to coordinate Medicare and Medicaid services. Shree Patel: and how the DSNP or Affiliated Medicaid plan provides these services, including long-term services and supports, and behavioral health services. Shree Patel: DSNPs need to address this item in addition to the others noted on this slide to earn credit for Factor 2. Shree Patel: Next slide. Shree Patel: For Factor 3. Shree Patel: The SNPs must describe how the ICP is maintained and updated based on changes in health status or care transitions. Shree Patel: An new for CY2027, SNPs must address where the ICP is documented and stored, specify how the enrollee and or their caregivers are provided with copies or electronic access to their ICP. Shree Patel: Detail how the plan ensures that the ICT, provider network, appropriate stakeholders, and enrollees and or their caregivers have access to the ICP, as well as the delivery mechanism for providing the ICP to these stakeholders. Shree Patel: For example, mail, fax, patient portal, etc. Shree Patel: Next slide. Shree Patel: For MOC2E, the ICT also had a few updates for this year. First, for Factor 1, plans must include the process used to determine the membership of the ICT, in addition to describing the composition of the ICT. Shree Patel: For Factor 2, beyond describing the roles and responsibilities of ICT members, their relevant training, and facilitation of enrollee and caregiver involvement in the ICT, the SNP also needs to describe how it invites enrollees and caregivers to participate as active ICT members Shree Patel: And provides them with needed resources. Shree Patel: Next slide. Shree Patel: Newly emphasized and clarified for this year, for Factor 3, SNPs must explain how they analyze enrollee needs and outcomes data to 1 evaluate and continually manage and improve the health status of SNP enrollees. Shree Patel: And two, implement and manage changes and or adjustments to the ICT composition as needed. Shree Patel: For Factor 4, please note that the new DSNP-only requirement to explain how the ICT coordinates with Medicaid providers when they are needed Medicaid-covered medical or social services that the plan does not cover if applicable. Next slide. Shree Patel: MOC2F is all about care transition protocols. Care coordination is required for all enrollees and is not limited to medium and high-risk stratified enrollees. Shree Patel: For Factor 1, the following are new requirements for this year. Shree Patel: SNPs must explain the process used for both planned and unplanned transitions. Shree Patel: For planned transitions, the MOC must describe the steps that take place before, during, and after the transition occurs. Shree Patel: For unplanned transitions of care, the MLC must describe the steps taken during, if known, and after the transition occurs. Shree Patel: In addition, DSNPs only must explain how the plan will coordinate with providers for Medicaid-covered services during care transitions. Shree Patel: For Factor 3, please don't forget to detail the process and methodology used to transfer ICP elements between care settings when an enrollee experiences a transition in care. Shree Patel: This is an item that plans sometimes forget to address. Shree Patel: Lastly, and new for this year, SNPs must describe the method for providing enrollees and their caregivers access to personal health information. Shree Patel: Next slide. Shree Patel: Again, 3 new DSNP-only requirements were added to MOC2 for CY2027. Shree Patel: DSNPs must address these requirements to earn credit for the associated factor. Shree Patel: DSNPs must fulfill these requirements in addition to the other requirements of the specified factor to earn credit. Shree Patel: The DSNP-only requirements do not impact the total number of factors evaluated for the element. Next slide. Shree Patel: For MOC3A, Specialized Enterprise of the Provider Network, the order of prior factors 3 and 4 were switched. Shree Patel: For Factor 3, which was about provider collaboration with the ICT, SNPs must now specifically address how providers collaborate with SNP enrollees and contribute to the ICP. Shree Patel: This is in addition to the other members of the ICT, so please make sure to speak to Provider Collaboration with the SNP enrollee specifically. Shree Patel: For Factor 4, please don't forget to specify the frequency for providing… for updating provider information in addition to the general process for doing so. This is a factor plans have missed in the past due to the omission of the frequency of updates. Shree Patel: Next slide. Shree Patel: For MOC3B, clinical practice guidelines and care transition protocols, prior factors 2 and 3 were combined, reducing the total number of factors from 4 to 3. Shree Patel: In addition, SNPs are now required to do the following for CY2027. Shree Patel: For Factor 1, describe the methods used to monitor, track, and verify compliance with clinical practice guidelines and nationally recognized protocols. Shree Patel: For Factor 2, detail the oversight of vulnerable enrollees for whom clinical practice guidelines were modified. Shree Patel: And for Factor 3, detail how care transition protocols are used both internally and by contracted providers to maintain continuity of care. Shree Patel: Next slide. Shree Patel: For MOC3, MOC 3C is about MOC training for provider network staff. Shree Patel: We have a few reminders for Factor 1. Be sure to describe the implementation of provider training and demonstrate the evidence that MOC training is made available to all appropriate in-network and out-of-network providers. Shree Patel: Renewal submissions must include a sample of actual slides and or training materials, whereas initial submissions may detail the content of training materials and or provide slide examples. Shree Patel: For Factor 4, please note that SNPs must specify the strategies used to encourage training completion. Shree Patel: This is a shift in focus over the last year, when focus was on actions taken when training was incomplete versus the use of proactive strategies to support training completion. Shree Patel: And with that, I'm going to hand it over to Laura to complete MOC4. Laura Zwolinski: Thank you, Sri. Laura Zwolinski: So for MOC4A, the Model of Care Quality Performance Improvement Plan, we wanted to note two things. Laura Zwolinski: First, new this year for Factor 4, plans need to describe how the goals established for the overall model of care performance and enrollee health outcomes are integrated into the overall performance improvement plan. Laura Zwolinski: The plan also needs to detail the process used to determine if goals and outcomes are met or not met. Laura Zwolinski: This factor focuses on a description of the processes themselves, rather than on the determination of whether specific goals or outcomes were achieved. That is a requirement of the next element we'll review. Laura Zwolinski: Second, Factor 5 is new this year. It requires SNPs to describe the process used to systematically identify enrollees that have received no covered Medicare services during a defined time period. Laura Zwolinski: The response must provide information on the actions taken by the SNP Laura Zwolinski: to identify and connect with these enrollees. The purpose of this factor is to identify members who have received no services so that the SNP can implement processes to encourage these members to obtain primary and preventive care services that may be warranted for their individual health status. Laura Zwolinski: Next slide. Laura Zwolinski: For MOC 4B, measurable goals, factor 4, which is the determination of goals met or not met, and 5, actions taken when goals are not met, were combined into a single factor, reducing the number of factors from 5 to 4. Laura Zwolinski: Factor 1 now focuses specifically on overall model of care performance goals for the new model of care. Laura Zwolinski: For example, improving access and affordability, improving care coordination and appropriate delivery of services through direct alignment with the HRA, ICP, and ICT, and enhancing care transitions across providers and settings. Goals must be measurable and specific. Laura Zwolinski: SNPs must include specific data sources, benchmarks, and the timeframes and frequencies used to measure, evaluate, and achieve them. Laura Zwolinski: We want to emphasize here that SNPs are required to include a goal for HRA, ICP, and ICT completion to meet this factor. All three of these goals must be set to 100%. Laura Zwolinski: Please do not list goals as to be determined or TBD, as this does not meet the requirements for this factor. Laura Zwolinski: Again, these goals are specific to the new model of care, or the one you are submitting for approval. Laura Zwolinski: Next slide. Laura Zwolinski: Factor 2 now focuses specifically on enrollee health outcome measure goals for the new model of care. Laura Zwolinski: For example, ensuring appropriate utilization of services for chronic conditions and preventive health services. Laura Zwolinski: Again, goals must be measurable and specific, SNPs must include specific data sources, benchmarks, and the timeframes and frequencies used to measure, evaluate, and achieve goals. Laura Zwolinski: Again, do not list goals as TBD. Laura Zwolinski: And these goals, again, are specific to the new model of care. Laura Zwolinski: Factor 4 requires plans to include a determination of whether each goal of the previously approved model of care was met or not met. Laura Zwolinski: And requires specific data, results, and the goal determinations themselves. Laura Zwolinski: If there is a specific reason that your plan has limited data and results for goals, please specify the reason in your response. For instance, indicate that you are an initial submission or a renewal submission that just began operations in January 2026. Laura Zwolinski: Renewal mocks include a description of the specific actions they will take to achieve or modify any unmet goals in the new model of care, including a description of the remeasurement and analysis process. Laura Zwolinski: This table illustrates how plans can address the requirements specified for overall model of care performance goals for Factor I and Factor 4. Laura Zwolinski: The first 5 columns, shaded in blue, present the information required for Factor 1. Laura Zwolinski: The plan must identify in detail the specific measurable goals it will use to measure overall performance in the new model of care being submitted for approval. Laura Zwolinski: To meet Factor 1, the table provides a description of each goal, the quantified goal itself, The current benchmark? Laura Zwolinski: The data source is used to collect information required to analyze goal performance, and specifies the measurement frequency. Laura Zwolinski: The specific goals in this example include access and affordability goals, in addition to HRA, ICP, and ICT completion goals. Please note that this is not an exhaustive list of goals, and the goals for your plan likely include additional performance goals, such as care transition or member satisfaction goals. Laura Zwolinski: I wanted to note that the three required care coordination goals for HRA, ICP, and ICT are all included here and set to 100%. Laura Zwolinski: This level of detail is required for both renewal and initial plans to meet Factor 1. Laura Zwolinski: For renewal plans to meet the requirements related to overall model of care performance goals for Factor 4, which requires a plan to specify whether the goals of the previously approved model of care were met or not met. Laura Zwolinski: The last three columns of the table, shaded in red, have been included beyond the first 5 columns to provide the quantified goal results. Laura Zwolinski: A designation of whether the goal was met or not met, and when and how frequently the goal will be remeasured. Laura Zwolinski: SNPs must capture information, all column topics in this table, to meet Factor 4. Please note that beyond the table itself, renewal plans also need to provide an action plan for goals not met and address how, they will be revised and remeasured. Laura Zwolinski: We recommend that plans do use a table to provide information for these factors. However, a narrative approach is acceptable if the necessary details are included. Laura Zwolinski: We also want to point out that this table assumes identical goals for the previously approved and new model of care. Laura Zwolinski: And this is for ease of illustration purposes only. Your model of care will likely have different goal targets, or even different goals, for the new goals in factor 1, and the previously approved goals in factor 4, based on your performance evaluation. Laura Zwolinski: Please note that to meet Factor 4, renewal plans also need to report the prior model of care's health outcome goals, results, and determinations of met and not met, in addition to these overall mock performance goals. So that would include both. Next slide, please. Laura Zwolinski: For MOC 4C, measuring patient experience of care. Laura Zwolinski: Prior factors one, which is the survey description, and two, which is the survey rationale. Laura Zwolinski: We're combined under Factor 1. SNPs also now need to address the following additional requirements for CY2027. Laura Zwolinski: For Factor 2, describe the methodology, that is, the modes, attempts, and frequency used to administer each enrollee experience survey, and detail the sample size for each survey. Laura Zwolinski: Renewal submissions should provide the actual sample size for each survey used. Initial submissions may provide an estimate for each. Laura Zwolinski: For Factor 3, detail how results are used to implement new programs that target areas for improvement. Laura Zwolinski: For Factor 4, describe the process used to address issues identified through survey responses and the steps taken to address those issues. Laura Zwolinski: Next slide. Laura Zwolinski: Lastly, Prior Element 4D, which was about ongoing performance improvement evaluation, was deleted this year, and that shifted prior element E, dissemination of MOC quality performance results, to new Element D. Laura Zwolinski: Beyond this, Prior Factor 3, which was a description of ad hoc communications, was deleted. Laura Zwolinski: In addition, New Factor 4 was added, and requires SNPs to describe how performance improvement results and updates will be documented. Laura Zwolinski: And that wraps up our review of the key changes at the element and factor level for CY2027. Laura Zwolinski: Next slide, please. Laura Zwolinski: In terms of a few reminders that we have, recordings and slides for all four Model of Care training sessions are posted to the SNP approval website under the Resources section. Laura Zwolinski: The next pre-submission technical assistance call will be held from 2 to 4 p.m. Eastern Standard Time on April 16th, 2026. Laura Zwolinski: The CURE TA call is scheduled from 2 to 4 p.m. Eastern Standard Time on August 4th, 2026. Plans that score less than 50% on one or more elements, or those that score less than 70% overall, are required to cure and should attend this session. Laura Zwolinski: The recordings from all TA calls will be made available to plans via the SNP approval website. Laura Zwolinski: Next slide, please. Laura Zwolinski: Please note that we included a short post-training survey for each of the four model of care trainings to collect comments and feedback. Laura Zwolinski: To access these surveys, please click on the links embedded in the slide deck once posted to the SNP approval website, and we'll use any results received to improve future training sessions, and we thank you in advance for taking the time to complete these surveys. Next slide. Laura Zwolinski: Okay. Laura Zwolinski: So that concludes our updates, clarifications, and points of emphasis for CY2027. So we're now going to open it up for any questions that you may have. Please feel free to raise your hand, or to ask your question live, Laura Zwolinski: to submit, sorry, to ask your question live, or, to submit questions via the Q&A feature. Shree Patel: Thank you, Laura. I believe we have one hand raised already, so Madeline, if you can go ahead and let Kirsten unmute. Madeline Vancott: Yes, I will go ahead and do that. Madeline Vancott: Alright. Madeline Vancott: Kirsten, you should now be able to speak. Laura Zwolinski: Kirsten, are you able to unmute yourself? Kirsten Rhodes: This is Kirsten. Laura Zwolinski: Hi, good afternoon. Kirsten Rhodes: I apologize, I don't know how I raised my hand. I think I was trying to get to the Q&A, and I must have accidentally hit that. I don't have questions at this exact moment. Laura Zwolinski: Okay, well, thank you so much, appreciate that. Madeline Vancott: Okay, we have another hand up from Linda Lee. So, Linda, I will go ahead and give you permission to… Madeline Vancott: Unmute, and you can go ahead and answer, ask your question. Shree Patel: Linda, are you able to unmute? Also, if we can't reach you, you can go ahead and put your question in the Q&A function, and we can read it out loud. Linda Lee: Okay. Linda Lee: I don't know if you can hear me. Shree Patel: We can hear you now, Linda. Linda Lee: Oh, perfect! Thank you very much. This is Linda Lee with Medical Card System, Inc, a health plan in Puerto Rico. I had submitted two prior questions in the Q&A, and I hope it's alright if I ask this third one. Linda Lee: I was wondering if you could please provide examples of partnerships Linda Lee: Established with community resources. And also, what kind of evidence is required to confirm that a partnership is established? Laura Zwolinski: Thank you so much, for your question, Linda. So in terms of, Laura Zwolinski: some of the, partnerships that we see. We see… Laura Zwolinski: Things like, partnerships with Meals on Wheels, or partnerships with, Laura Zwolinski: Some, sort of specialized transportation services, a variety of, of different, Laura Zwolinski: Partnerships, kind of come through, but we don't have any specific requirements on what defines a partnership. Laura Zwolinski: I think we leave that to the discretion of the SNP. Laura Zwolinski: to identify what partnerships are meaningful to meet the needs of their most vulnerable enrollees. And so, you know, we kind of see a mixed bag of things, but we don't have Laura Zwolinski: Any sort of, set, strict requirements on what constitutes a partnership, if that is hopefully helpful. Linda Lee: No, that's very helpful, because my other question, originally was, can you please expand on what are considered services for the most vulnerable? And I think you've, you've just basically, answered that. Linda Lee: you know, like, I… because I had asked in addition to transportation. So, okay. Would you mind if I asked you the other question I had in the chat? Laura Zwolinski: Sure. Linda Lee: Okay, thank you very much. Linda Lee: basically, we are a, a HIDE, a highly integrated, dual eligible, plan, and we were wondering, our plan enrollees receive their benefits Linda Lee: from… from us, the DSNP plan solely, and, basically under their Medicare Advantage benefits. Is it acceptable for us to kind of develop some language addressing this? Linda Lee: in, you know, the various factors, such as Mach 2, Element D, factor 2, to explain this in that matter, or is there more of an explanation that's needed? Daniel Lehman: Hey, Laura, this is Dan. Linda Lee: Hi, Dan. Daniel Lehman: So… I, as I noted in the, Daniel Lehman: Q&A response, I think you can provide, a rationale around, you know, being a Heidi SNP and how. Linda Lee: Yes. Daniel Lehman: Medicare and Medicaid services are coordinated Daniel Lehman: Through your plan, you can provide some examples. As I noted, it doesn't have to be exhaustive, you know, it doesn't have… Daniel Lehman: everything under the sun. I think that would be… be fine to just note some of those. Daniel Lehman: That makes sense. Linda Lee: It makes perfect sense. Thank you very much, Dan. Daniel Lehman: Excellent. Linda Lee: concludes my questions. Thank you very much. Daniel Lehman: No worries. Laura Zwolinski: Thank you, Linda. And also to expand on some of the other, sort of, services we see, we also see, for the most vulnerable populations, we also see some specific social services. Laura Zwolinski: medication therapy and costs and end-of-life planning often. And then in terms of care management practices for the most vulnerable enrollees that are sort of specific to them, we often see, Laura Zwolinski: you know, the plan indicating that there's more frequent connection with the enrollee by the care manager based on the enrollee's higher acuity, and, you know, that leads to more frequent ICP updates and connection with the ICT. So, in terms of the care management practices, that's often what we see there. Laura Zwolinski: Some plans have, have, defined and addressed these, sort of newly specified items this year in the past, so some plans may, in fact, already have, this information from their prior model of care as well, so I wanted to note that. Laura Zwolinski: I… I do know that there are a variety of questions in the chat, which we'll begin to get to, but one that we have, received a few times Laura Zwolinski: Is about the, the model of care, matrix for this year. Laura Zwolinski: And, plans asking how they should, sort of, complete that, given that it's not in, a table… a table format this year. Laura Zwolinski: And so, just so everyone, has a chance to, to hear this response, because we did receive it. Laura Zwolinski: I think multiple times in the Q&A, Laura Zwolinski: So, in terms of completing the matrix, there are sort of two options for doing so this year. Laura Zwolinski: And so the first one, plans can go ahead and use the matrix and indicate the page number location of each of the model of care elements and factors by listing page numbers next to the text description in the matrix itself. Laura Zwolinski: And then the other options plans have is to submit a standalone table of contents in place of the model of care matrix. Laura Zwolinski: If the table sort of accurately documents the description of the element and factor, and then the associated page number. Laura Zwolinski: So either of those options are available to plans in terms of what works best for you. But regardless of the option used, SNPs must identify all of the plan affiliations. Laura Zwolinski: To identify similar models of care submitted for review. Laura Zwolinski: So hopefully that clarifies the response to that question, and welcome Dan or anyone else on the NCQA team to further elaborate on that if needed. Daniel Lehman: This is Dan. No, that… that was very helpful, thank you. Laura Zwolinski: Okay. Laura Zwolinski: Do we have any other hands raised? Madeline Vancott: Yes, we have another hand raised from TJ Mogulsang, so I will go ahead and allow to speak. TJ, you should have the option to unmute, and you can go ahead and ask your question. TJ Vogelsang: Oh, sorry, I didn't mean to have my hand raised. My apologies. Laura Zwolinski: No worries! Laura Zwolinski: Thank you, Tina. Laura Zwolinski: Okay, well, why don't we see if anyone else has, Laura Zwolinski: a question they'd like to ask live, we can, I think, start moving through some of the open questions in the… in the chat. Madeline Vancott: Laura, we do have another hand raised, sarah Ferguson with Devoted Health. Sarah Ferguson (Devoted Health): Hi there, can you hear me? Madeline Vancott: Yes. Laura Zwolinski: Yes. Sarah Ferguson (Devoted Health): Great. So I just had a question to make sure I fully understand the guidance on the mock matrix. So, would we be… so let's say I'm submitting a DSNP on contract H number 1234. Sarah Ferguson (Devoted Health): I would fill out that top page of the matrix with the, contract name and contract type. Sarah Ferguson (Devoted Health): And then I could just include a table of contents at the bottom, sort of, like, underneath all of the, text that outlines all of the requirements. I could just upload the table of contents with all the page numbers, and then I would subsequently add a table Sarah Ferguson (Devoted Health): below that, that has all of the similar models of care that, are being submitted, similar to that, that contract. So essentially, it would be, like. Sarah Ferguson (Devoted Health): a page… one… one document with sort of three sections, the form for the mock matrix, my table of contents, and then a table of all similar models of care. Is that what, is envisioned for the mock matrix submission? Laura Zwolinski: I think that is something that would be, you know, certainly sufficient. I think, Laura Zwolinski: In terms of the model of care matrix, I believe towards the top there is one area where, Laura Zwolinski: Plans can go ahead and include any affiliated models of care there. Laura Zwolinski: So that's another option if you, you know, would like to include that information in the top area. Laura Zwolinski: But… but yes, what you described is… is perfectly fine. It's also, and addresses all of, the information that we're looking for. It's also. Laura Zwolinski: sufficient for a plan to just add in the page number next to what's already included in the matrix document text. Laura Zwolinski: that is not in a table, just, you can include, you know, like, page 7 next to the information, for, for instance, MLC 1A, Factor 1 language, you can include a page number right next to it. But you do also have the option of submitting a standalone Laura Zwolinski: table of contents, it doesn't have to be included in the… in the matrix document, if… if that's the… the route that… that you'd like to go as well, so… Laura Zwolinski: Does that clear things up? Laura Zwolinski: So what you described is perfectly acceptable. Sarah Ferguson (Devoted Health): Perfect, that's, that's helpful, thank you. Laura Zwolinski: Okay, sure. Madeline Vancott: Okay, we have a… Nevermind. Shree Patel: Okay, and with that, we can start to move on to the Q&As. Shree Patel: The first one we have up here is Shree Patel: going to be MOC2A, Factor 1, Shree Patel: The question asked is, this factor asks for a description of the health plan staff functions to support coordination of care for SNP members. Shree Patel: An explanation of staff that conduct behavioral health counseling is specifically required. Shree Patel: Behavioral health counseling services are provided by contract network providers, rather than our employed health plan staff. Shree Patel: Does CMS slash NCQA want to see an expansion of how behavioral health counseling services are managed by the plan such as authorization, payment, and referral functions? Or is the information needed here related to the qualifications of network providers who deliver this care? Laura Zwolinski: Yeah, thank you so much for your question. You know, I think what we're looking for, in Factor 1 for 2A, specific to behavioral health counseling, is, one, we certainly want to understand, Laura Zwolinski: the type of providers or clinicians that are responsible for providing health counseling, if that's sort of a delegated activity, we would want to know that and understand that piece. Laura Zwolinski: And we'd like to know, you know, what kind of behavioral health counseling providers, Laura Zwolinski: you know, you are sort of overseeing and working with social workers, etc. So, I think there's… the first piece is, identifying who these providers are. I think specifying that, you know, you are overseeing them. Laura Zwolinski: And third, making sure that you specify what their, credentials and licensing are. Laura Zwolinski: Are there any follow-ups on that… on that question? Shree Patel: Thank you, Laura. I do see that someone has their hand raised, and it was an anonymous question, so Madeline, if you want to… Madeline Vancott: Yes. Shree Patel: That mute. Madeline Vancott: You should have the ability to speak at this point. Madeline Vancott: Marie Tess, we're not able to hear you. Madeline Vancott: Are you able to unmute? Marites Yrastorza: Hi, can everyone hear me? Madeline Vancott: Yes, we can hear you. Marites Yrastorza: Oh, perfect! Thank you so much. So, my question is with regards to a slip mark submission as it relates to contracts. Marites Yrastorza: What it is, is our current organization offers CNDISNIP, so it's not new to us. So, the situation that we're encountering now is we do have an existing MA contract. Marites Yrastorza: That is non-SNP yet, but I was informed that this SNP contract will be consolidated Marites Yrastorza: under that new contract that doesn't have any SNP yet. Marites Yrastorza: And I was informed that this particular contract will be filed as an initial application. Marites Yrastorza: So, my question is, would the new exist… with the new existing MA contract that doesn't have any SNP yet, and we are forecasting a SNP to be Marites Yrastorza: to be, incorporated in that one after the bid submission, are we required to file a new mock for that specific age contract? Marites Yrastorza: Considering it was filed as initial application, rather than a service area expansion, bit complicated. Daniel Lehman: Yeah, and, and, I'm gonna put in… Daniel Lehman: our, CMS Part C policy mailbox, address. I think Daniel Lehman: This might be one we want to discuss in more detail with you. Marites Yrastorza: pointing. Daniel Lehman: The only thing I will… the only thing I will say is that, you know, every SNP needs to have a mock that's approved by NCQA. Daniel Lehman: And, so I just want to understand your… Daniel Lehman: specific situation in greater detail to ensure that I'm giving you Daniel Lehman: you know, the most accurate information, so I'm gonna put our mailbox in there. And please feel free to reach out to us. Marites Yrastorza: Okay, thanks, Dan! Daniel Lehman: No worries, thank you. Shree Patel: Thank you for your question. We will now move on to another Q&A. Shree Patel: In MOC1, there is a list of demographic categories to report on general and the most vulnerable populations. Shree Patel: How should this be managed if there is an item listed that Shree Patel: Is that… is collected constantly, and is not something that is available on the most vulnerable populations. Shree Patel: The MOC must describe demographic details of general and most vulnerable popu- SNP populations. However, this requires provision of population demographics, including, but not limited to, those outlined in the scoring guidelines. Laura Zwolinski: Yeah, thank you for the question. Laura Zwolinski: So, we've run into this a couple of times, in the past, particularly with the, education demographic detail. Laura Zwolinski: If there is, a demographic Laura Zwolinski: Data point that is not collected. Laura Zwolinski: we have asked SNPs to let it, you know, identify that that has not… that's not collected, and typically, we have asked them to provide us with Laura Zwolinski: some proxy data for that particular category of demographic information. So this is something that, again, we have seen with the education element in the past. Laura Zwolinski: For the remaining, Laura Zwolinski: data… data categories, we do typically, receive that information for the plan's membership, but, for that education element, that is sometimes, Laura Zwolinski: you know, not available, and please just indicate in your model of care that it is not available, and include proxy data, and indicate why, you know, that proxy data approximates the… Laura Zwolinski: the target populations in your, in your SNP. Shree Patel: Thank you, Laura. Shree Patel: Next question pertains to MOC2B, Factor 1. Shree Patel: The question is, this factor asks for a summary of the evidence-based tools used in developing the HRA tool. What type of evidence is needed? Will a listing of evidence-based sources be sufficient for this factor? Laura Zwolinski: Yeah, thank you for this question, and I think this is a question that, well, this is a factor that we've received some questions on, through the… through the mailbox, the TA mailbox, and I think there might be others also in the Q&A here. Laura Zwolinski: But essentially, overall, what we're really looking for is for… Laura Zwolinski: Plans to describe, in some manner. Laura Zwolinski: how the HRA tool or their tools specifically assess the medical, functional, cognitive, psychosocial, and mental health needs of enrollees to showcase, essentially, that the tool is comprehensive. Laura Zwolinski: And so, as part of that response, plans may, you know, also provide examples of the HRA tool or tools that they're using. In either case, really the plan needs to delineate how the tool used assesses these specific domains. Laura Zwolinski: In the past, sometimes, you know, plans would maybe Laura Zwolinski: indicate that this tool assesses these domains, but didn't sort of make a further connection about how specifically this tool assesses the, you know, the medical domain, or the cognitive domain. And so, this particular factor was expanded Laura Zwolinski: So that we're able to sort of understand that particular piece of the HRE tool. Shree Patel: Thanks for the… You too, Laura. Laura Zwolinski: Yeah, sure. Anything, anything, Dan or others that you'd like to add there? Daniel Lehman: No, I appreciate that response. Shree Patel: Sounds great, we can move on to the next question. Shree Patel: This question is for MOC2D. Can you explain how factors 3 and 4 are different? The detailed description for these factors seems that they cover very similar information. Shree Patel: I think I can speak a little bit on this. For Factor 3, it's pertaining to the process for how ICP is maintained and then disseminated to the appropriate stakeholders. Shree Patel: So, we're looking for a description of how the ICP is maintained and updated during these transitions of care or changes in health status. For example, this can be information that's collected from HRA assessments. Shree Patel: And, as a response, the SNP addresses where it is documented. Shree Patel: And… whereas Factor 4 pertains to the communication of updates, so… Shree Patel: this is how is that information then shared over to other SNP personnel or network providers and other stakeholders, as well as the enrollees and their caregivers. How are they informed on these decisions and updates? Shree Patel: Anything Laura or Dani would like to add? Laura Zwolinski: No, thank you so much, Trey. Shree Patel: Sounds great. We'll move on to the next question. This is pertaining to MOC 4A, Factor 5. Shree Patel: First, this is a three-pronged question. So, the first question is, how does CMS define no covered Medicare services for Factor V, Parts A and B, claims only, or should Encounter data, preventative services, or Supplemental benefits be considered? Laura Zwolinski: Dan, is there any information you'd like to provide from CMS's perspective on this one? Daniel Lehman: I am completely sorry, I was answering a question in the box. Can you please repeat the question comment? Shree Patel: Yes, of course. So, the first question is pertaining to MOC 4A, Factor V, identification of enrollees with no covered Medicare services. Shree Patel: The question is, how does CMS define no-covered Medicaid care services for Factor V? Parts A and B claims only, or should encounter data, preventative services, or supplemental benefits be considered? Daniel Lehman: That's a great question. I, I think, Daniel Lehman: In this case, we're literally discussing, whether there's no evidence of services being provided, and I would say A, B, Daniel Lehman: or, supplemental benefits. We're really trying to… Daniel Lehman: Identify enrollees, who, who… Daniel Lehman: You know, appear not to be… Receiving, any services from the plan. Daniel Lehman: I don't know if others have thoughts on that. Shree Patel: Nothing to add there, but the second part of the question is, should Part B… sorry, should Part D utilization be included or excluded from this determination? Daniel Lehman: I would say included. So meaning, you know, if there seems to be a clear record of prescription fills, that would be evidence of Daniel Lehman: services being provided. So, yeah, no, I appreciate that inclusion of that in the question. Shree Patel: Of course, and the last part of this question, sorry to keep pulling you into the stand, is for DSNPs, should members Shree Patel: receiving only Medicaid-covered services be included in the no Medicare services population? Daniel Lehman: So, it's true, they would be receiving services on the Medicaid side. However, I would be concerned if Daniel Lehman: there's no evidence of Medicare services being covered. So I think we… we would be interesting… interested in knowing that. Daniel Lehman: And plans should make note if there are internal difficulties in terms of identifying or, Daniel Lehman: threading out, you know, difference between Medicare and Medicaid services in terms of doing that review, but… Daniel Lehman: But I would imagine we would want to know if there are no Medicare services being Daniel Lehman: provided, but there is evidence of Medicaid, if that makes sense. Shree Patel: Yes, appreciate that. Shree Patel: The next question on our Q&A is regarding 2C, Factor III, Shree Patel: Plans do not necessarily need to use Clanton's data to verify internal staff provided a face-to-face encounter. Can plans use care management notes or HRA completion dates to verify encounters with internal staff? Shree Patel: The MOC guidelines require an explanation of how claims are used to verify encounters. Laura Zwolinski: Yeah, thank you for that question. Excuse me, and Dan, please let us know if you have different thoughts on this. Laura Zwolinski: But yes, in terms of the internal encounters that you noted, I think it is certainly acceptable for you to describe what process you are, in fact, using to determine whether or not Laura Zwolinski: a face-to-face encounter has occurred, and, you know, I would just sort of, you know, make sure that you're specifying that that's for your internal piece there. Daniel Lehman: Yeah, and speaking to the HRA notes, yeah, I mean, to me, that's, you know, we… we have emphasized since, Daniel Lehman: The legislation was passed, and we adopted a regulation around it, that… you know, an HRA, Daniel Lehman: episode would count as a face-to-face encounter. So, you know, evidence of that would be, sufficient. Shree Patel: Thank you for that addition. We actually have a follow-up for the HRA question. Shree Patel: This is, can you provide a bit more detail about what you're looking for for this question? Examples of questions in each domain, or attaching the tool in the appendix? Laura Zwolinski: I'm sorry, Shree, can you… can you repeat that question? Shree Patel: Yes. Laura Zwolinski: I'm not seeing that. Shree Patel: Yes, it just came in as we were answering the HRA question. It is a follow-up to it. Shree Patel: And it says, can you provide a bit more detail about what you are looking for? Examples of questions in each domain, or attaching the tool in the appendix? Laura Zwolinski: Sure, yeah, either of those things, is acceptable. Some plans do include a copy of the HRE tool, to, sort of provide evidence that, the variety of the domains that we mentioned are covered. Laura Zwolinski: Some plans, alternatively, they will sort of do a synopsis of a few questions under each of those domains to showcase how the tool is assessing those areas of care for the enrollee. Either of those things are acceptable. Shree Patel: Appreciate that, Lauren. Shree Patel: We'll move on to the next Q&A question. This is pertaining to MOC 4A, Factor 5. Shree Patel: This is a three-pronged question, and the first question is, what timeframes does CMS consider reasonable for the defined period? Example, 6, 9, 12 months, etc. Laura Zwolinski: Yeah, I can start off on this, and Dan, if there's anything that you'd like to add, in terms of your question about the defined time period, you know, no timeframe is specifically defined. However, you know, we would anticipate… so it really the… Laura Zwolinski: We expect the plan to tell us what their process is, you know, and we would anticipate a common cadence that we might see for that review would be quarterly, or, you know, even every 6 months to enable proactive outreach and engagement attempts prior Laura Zwolinski: to members, you know, being enrolled for a full year, but I think at this point, you know, we're asking the plans to tell us what their plan is to make sure that they are able to Laura Zwolinski: Identify and assist enrollees that haven't received any services to do that in the event it is beneficial for, for their current health status. Daniel Lehman: Yeah, and I don't think I necessarily have anything to add to that. Thanks, Laura. Shree Patel: In follow-up to that question, does CMS or NCQA expect different monitoring periods for new versus established enrollees, or by SNP type? Daniel Lehman: No, I wouldn't think so. You know, I don't think we're prescriptive to that extent. I think we're just looking for evidence of a process. Laura, does that make sense? Laura Zwolinski: Yeah, I agree that that is… that is, what we are… are looking for, for plans to describe for. Laura Zwolinski: For this particular factor. Shree Patel: Appreciate that. And the last for this question pertaining to MOC4A is, is the rolling review period acceptable, or should plans use a fixed calendar intervals? Laura Zwolinski: Yeah, I think, again, we're looking for you to, share your process with us. Laura Zwolinski: And at this time, there's no… no specified requirements around that. Laura Zwolinski: In terms of… Response to this particular factor in the model of care. Shree Patel: Thank you, Laura. And Madeline, I believe we have a hand raised. Madeline Vancott: Yes, we do. Madeline Vancott: Alright, you should have the option to unmute. Marites Yrastorza: Hi, Madeline, can everyone hear me? It's me again. Madeline Vancott: Yes, we can hear you. Marites Yrastorza: Okay, thank you. Yeah, so referencing back the new process wherein we have to specify how do we Marites Yrastorza: Emphasize the caregiver or the enrollee's involvement in the care planning. Marites Yrastorza: Is CMS expecting us that there should be at least an outreach before a care plan be created? Marites Yrastorza: Or is it sufficient to outline in our process, since there is, like, a strict timeline now, on how soon do we send out initial care plans. Marites Yrastorza: that we are to leverage the responses from our HRA, and later on, reach out to the member. Marites Yrastorza: I think it's, like, a sticky point at this time. I just wanted to be well-versed in what is the expectation from CMS. Daniel Lehman: Yeah, so this is Dan. I know we have spoken to this in the, Daniel Lehman: Find a rule that, Daniel Lehman: noted the reg change in 42211F. You know, I think the emphasis here is on person-centered and, that the, enrollee and or their caregiver has, Daniel Lehman: influence on… Daniel Lehman: on the development of the ICP, but we understand that's not always possible for that to occur, but I think the expectation is that the plan would make some effort to include them in that process. Daniel Lehman: We have historically said that, Daniel Lehman: you know, when it's not possible to have input from the enrollee or their caregiver, that plans can develop an ICP, based on, claims data or other Daniel Lehman: data, such as, you know, information coming in from the HRA. I think what we are trying to, Daniel Lehman: Avoid is sort of… a, lack of a better word, sort of a… Daniel Lehman: cookie-cutter sort of ICP that's developed that's not terribly specific to that individual enrollee. So I hope… I hope that answer, Daniel Lehman: Helps you, but we're happy to do a follow-up, by email if, if… Daniel Lehman: If there are other specifics that you'd like us to address. Marites Yrastorza: Okay, I think so then, yeah. So it seemed that, you know, so we got, like, the CMS intent, of course, for the sake of our members, but I believe, that we can also draft some other avenues wherein at least there should… there should be, like, an input from the member Marites Yrastorza: or the caregiver, whether they come before the ICP creation, or maybe, like, like an outreach Marites Yrastorza: to discuss the care plan that's already in place, and perhaps, like, have a better input or, like, a revision later on if needed. I think I got it. Okay. Daniel Lehman: I think of the ICP as kind of a living document anyway, that, you know, gets updated, and so there may be a point in which, Daniel Lehman: it gets updated with additional feedback from the enrollee or their caregiver, and… and so I… I think, Daniel Lehman: you know, plans being mindful of that reality as well. But please follow up with us if you have additional questions. Marites Yrastorza: Okay, perfect, Ned, but thank you, thank you. Shree Patel: And we'll go back to some of our Q&A questions. Shree Patel: We have another two-pronged question here, the first being, are there enrolling categories CMS expects plans to exclude or separately address? Example, hospice, refusals, unreachable members, etc. Laura Zwolinski: Yeah, thank you, Sherry. I wonder if, Tina, if you'd be willing to… Laura Zwolinski: Clarify, your question in terms of addressing these enrollee categories for, a particular Laura Zwolinski: Element or factor. Laura Zwolinski: It's not clear, to me which particular element or factor this question relates to. Shree Patel: Tina, if you're here, you can go ahead and raise your hand, and we can have Madeline unmute you. Madeline Vancott: Yes, Tina, you should have the option now. Tina Cullins (UHC): Hi, thank you. Can you hear me? Laura Zwolinski: Yes. Tina Cullins (UHC): Perfect. Yes, so my question got separated from the title. So, this is related to 4A5. Tina Cullins (UHC): Again, so just wondering about those, enrollees who have no Medicare services, you know, do we need to exclude Tina Cullins (UHC): Or separately address these populations, hospice, or how do we handle the refusals or unreachable enrollees? Laura Zwolinski: Dan, does CMS have expectations, Laura Zwolinski: around this new factor for DSNPs. Daniel Lehman: You know, I'll be honest. Laura Zwolinski: Kind of jumping. Daniel Lehman: to the new factor to. Daniel Lehman: to make sure I'm addressing it accurately. Daniel Lehman: Often, we would rather have… Plans provide context. Daniel Lehman: Within their, mock matrix responses of why… how they would handle someone who's unreachable, unreachable, or in specific sort of care settings that would, impact, the ability to reach them. Daniel Lehman: I am… I would be concerned about setting, sort of, Daniel Lehman: Clear lines of, not including someone based on a particular health situation. Daniel Lehman: this might be one where, you know. Daniel Lehman: We would encourage you maybe to send a, Daniel Lehman: An additional message to us, to our inbox. Daniel Lehman: So that we could give you a more thoughtful response. Daniel Lehman: And we would be happy to put that in the Q&A as well, so that other Daniel Lehman: Folks in attendance could… could see our response. Daniel Lehman: I don't know if, NCK, Emily, if other folks have thoughts on it. Shree Patel: Nothing additional to add, but while we have Tina here, since it was a two-pronged question, if there's no additional comments, we can move on to the next one. Laura Zwolinski: Yeah, and I think that question can probably also be submitted along with the first question, just to be sure, like Dan mentioned, we're sort of giving thoughtful consideration to some of these good questions that we're receiving around the new DSNP. Laura Zwolinski: Only, sort of, components of the, the, the factors. Tina Cullins (UHC): Great, thank you. Laura Zwolinski: I'll submit that. Laura Zwolinski: Wonderful, thank you so much, Tina. Shree Patel: Okay, we'll move on to the next question. Shree Patel: In regard to MOC 4B, if we summarize goals for the new MOC submission in a table format, do you expect to see additional explanation outside of the table? Laura Zwolinski: Yeah, thank you for that question. Laura Zwolinski: So typically, plans do provide some sort of narrative explanation of the information in… provided in the table, if you provide a table. However, if you do provide all of the required fields and information as part of Laura Zwolinski: The table that you submit, that is not, that's not necessary in order to meet that factor. Laura Zwolinski: well, I should specify. Laura Zwolinski: If it's for factors 1 or 2, which are the goals of the new model of care. However, if it is for factor 4, which is about, an assessment of goals of the previously approved model of care. Laura Zwolinski: After you indicate whether or not a goal is met or not met. Laura Zwolinski: You would also need to provide information about how you are updating or revising goals not met, and your reassessment plan for those goals not met. So, it would depend on which factor you're trying to meet with the table. Shree Patel: Thank you, Laura. Shree Patel: The next one we have here is for MOC 4B. Is there a specific number of goals you expect to see for factors 1 and 2, aside from the required HRA, ICP, and ICT goals? Laura Zwolinski: Yeah, thank you for… for that question. Laura Zwolinski: So, we don't have a specified number of goals that we would expect to see. However, plans usually do submit a variety of goals that cover different topic areas. Laura Zwolinski: So for, for 4B, we typically would see, an improving access and affordability of care goal. Laura Zwolinski: beyond the, care coordination goals that you noted here, we often see, goals about enhancing care transitions across all providers and settings. We also, will sometimes, Laura Zwolinski: see goals related to enrollee satisfaction surveys. So there's a variety of things that we might see. We don't have a specified number of goals, and we're not prescriptive about Laura Zwolinski: the number of goals. But we, we typically do see, a sort of… Laura Zwolinski: Broad array of goals to cover different aspects of… of… The measurable goals. Shree Patel: Thank you, Laura. Shree Patel: Next question is for MOC3, the CPG for a member that may not be appropriate to follow the CPG as written. Shree Patel: The requirement to explain how a CPG can be altered and how it is documented. CPGs are posted on the provider portal. Diabetes care, for example. If a provider is managing the care of the member, approval is not required if the Shree Patel: Provider determines a medication is not appropriate, and we would not know this since it is a clinical management of their patient. Can you provide examples of the intent of these factors, please? Laura Zwolinski: Sorry, I was stuck on mute there. Laura Zwolinski: Yeah, so I think the… our intent is not to indicate that Laura Zwolinski: The guidelines themselves need to be updated. But just generally, overall, what is the process, to deliver care outside of the specified guidelines, should that need arise based on Laura Zwolinski: particular, you know, a particularly complex case, a vulnerable member, if that is something that happens at. Laura Zwolinski: You know, the clinical judgment level, to sort of just describe that process Laura Zwolinski: for us. And I think that sums up what we're, you know, generally looking for under these… under this set of factors here. Shree Patel: Next question is, what are your expectations for plans to communicate the SNP MOC slash outcome goals externally? What is required specifically in MOC 4B Factor 3? Laura Zwolinski: Let me just take a look at that. Laura Zwolinski: Yeah, I think, that's a great question, and I think there's, Laura Zwolinski: This is also sort of perhaps covered a little bit later on, under MOC4, Element D. Laura Zwolinski: In terms of, sort of, dissemination of. Laura Zwolinski: sort of process improvement, overall performance to stakeholders, and I think that that really is what we're getting at, sort of how stakeholders are kept apprised about, model of care performance improvement and goals. Laura Zwolinski: So, Laura Zwolinski: hopefully that's helpful. I do think that, that is touched on a little bit more under… under 4D. Shree Patel: Thank you, Laura. Next question is pertaining to MOC3, Shree Patel: Element C, Factor 1, there have been several provider requests that we accept assetations of trainings for the standardized CMS model of care training. Shree Patel: In the past, we have not accepted this, and required that providers complete our plan-specific training. Would another model of care training example from another plan meet this requirement? Daniel Lehman: This is Dan. I would say… I would caution, and say no, just given the way the regulation is currently written, that it has to be, you know, a training on the plans mock. Daniel Lehman: I think there are situations in which plans… Can… Daniel Lehman: Align trainings to cover the intent of individual mocks. Daniel Lehman: But we would… I think we'd want to know, Daniel Lehman: how those trainings are aligned in a way to do that. And certainly, if the SNP is unaware of a particular training being aligned. Daniel Lehman: To cover multiple, SNPs, I think there would probably be a concern on everyone's… Daniel Lehman: minds of that, so I would say, in general, probably not, but, Daniel Lehman: If the plan would like to follow up with us offline, if they are aware of something specific, we'd be happy to address that. Shree Patel: Thank you, Dan. Shree Patel: Next question we have is pertaining to MOC4D, Factor 4. Shree Patel: The question asks, what are you looking for in terms of how performance results will be documented? How is this information different from the examples of communication and modes required earlier? Shree Patel: in the element. Laura Zwolinski: Yes, thank you. I think this is just more about the storage mechanism versus the dissemination mechanism for this particular factor. Laura Zwolinski: In terms of the performance results. Shree Patel: Thanks, Laura. Shree Patel: We can go ahead and move on to the next question. Shree Patel: For MOC2B Factor 2, is it sufficient for the SNP to segment DSNP members into categories based on several factors, one of which being responses to the HRA? Shree Patel: Dan, do you have any insight into… Laura Zwolinski: I guess… so, just to clarify, this is about… Laura Zwolinski: Stratification of… of members, in… into different, risk tiers. Laura Zwolinski: So the question is, is it sufficient for SNP to segment DSNP members into categories based on several factors, one of which is responses to the HRA? Laura Zwolinski: Yes, we often see, plans Laura Zwolinski: use a sort of an amalgam of different factors to identify, their, you know, low, medium, high, and or, severe risk categories. Laura Zwolinski: Sometimes a plan will, you know, have just one or two criteria, sometimes it will be more than that, but it is not uncommon to sort of use a combination of factors to identify the categories themselves, and so that is something that can be done. Laura Zwolinski: That is something that would be sufficient, as long as you define that for each of the risk tiers. Shree Patel: Thank you, Laura. Laura Zwolinski: Are there any follow-up questions on that, or, any other information that… Laura Zwolinski: But CMS would like to add. Daniel Lehman: No, I appreciate your response, and I was gonna say that, Daniel Lehman: We… we are not, I think. Daniel Lehman: prescriptive in the sense of, setting expectations for stratification and… Daniel Lehman: A very particular way, and… and understand how, maybe. Daniel Lehman: Plans would approach it that way, if that makes sense. Laura Zwolinski: Yes, thank you. Shree Patel: Thank you for that. Shree Patel: Next question is, does NCQA anticipate removing the requirement to report on race as a part of the required demographics in MOC1, as CMS no longer allows plans to collect this data as a part of enrollment? Shree Patel: I'll have my NCQA colleagues weigh in after this, but I believe there is no requirement to report on race for Factor II in MOC 1 anymore. Laura Zwolinski: Yes, that's correct. Race is not included as a data element for, the demographic information that's collected in… or that we are requesting in MOC1. Shree Patel: Thanks, Laura. Shree Patel: So we are going to move on to the next question. Shree Patel: And that's going to be… Shree Patel: For MOC4, can a goal be set to 5 stars without giving an actual percent as cut point? Shree Patel: Change annually. Laura Zwolinski: Thank you for the… excuse me, I'm sorry. Laura Zwolinski: Thank you for the question. Laura Zwolinski: And yes, we… We do allow the use of, of, of stars as, Laura Zwolinski: you know, as part of, the plan's goals, they can certainly use that. However, I would caution, specifically for the ICP, HRA, and ICT goals, that those do need to be set to 100%. Shree Patel: Thank you for thought, Laura. Shree Patel: Next question we have up is… Shree Patel: Are all the members needs to have the ICT presentation slash discussion, or just to have a multidisciplinary team available to attend to their needs? Shree Patel: This also was an anonymous question, and it seems to be have cut off, so if anyone who may want to follow up on this question, please raise your hand to clarify. Shree Patel: Okay, we'll go ahead and move on. Laura Zwolinski: Let's, let's take a pause here and, see if there's any, just take another call for… Laura Zwolinski: Live questions, see if anyone has a question. Laura Zwolinski: That they want to ask live. Shree Patel: Alright, if there are no live questions, we can go back to our question and answers. Shree Patel: Next question is pertaining to factor… Shree Patel: Two, in MOC 1B, plan benefits are not typically only reserved for the most vulnerable. Rather, the most vulnerable may use more of a particular plan benefit or service that is especially helpful due to their conditions, etc. How should we frame this within the model of care? Laura Zwolinski: Thank you for that question. Laura Zwolinski: I think it is appropriate to frame it as you've asked the question here, in terms of the frequency of utilization for the most vulnerable population and the enrollees in that group. Laura Zwolinski: Sometimes, in terms of the, the actual, sort of. Laura Zwolinski: Partnership piece of it, not necessarily the benefits and care management piece, but… Laura Zwolinski: The, the partnership piece, we will see very, you know, very specific. Laura Zwolinski: partnerships to support that most vulnerable population, so we would certainly want to see that. But in terms of, Factor 2, please just, identify what you've indicated here, in your response to that factor. Laura Zwolinski: For the context. Shree Patel: Thank you, Laura. Shree Patel: Next question is, for community partnerships, we work with a vendor who establishes partnerships and gathers the resources on our behalf. Shree Patel: Is describing this and listing the partners they have established in the local SNP community and describing the services provided sufficient? Or does it have to be a list of direct partnership with formal agreements between the SNPs and the community organizations? Laura Zwolinski: A listing of the, the partners, that you noted are, are established. Laura Zwolinski: that is fine. It doesn't have to be, you know, a direct… you know, there's no formal agreement is needed. I know that we talked about this a little bit earlier on in the call. They don't need to be formal, formal agreements. Laura Zwolinski: So, listing any of those partners, in that SNP community and describing the services provided, would meet the intent of, of that factor in, in MOC, 1B. Shree Patel: Thank you, Laura. Shree Patel: Next question is, are all HEDIS-related goals required to be set to 5 stars? Shree Patel: I can go ahead and answer this question. HEDIS goals are scored on a percentage basis, so those pertaining to the model of care that are dealing with ICT, ICP, and HRA should be set to 100%, whereas HEDIS-related goals can be set to benchmarks. Laura Zwolinski: Correct, and NCQA and NCMS are not prescriptive on… Laura Zwolinski: You know, how you set your goals. Laura Zwolinski: even those related to HEDIS, it is up to the discretion of the plan to identify Laura Zwolinski: you know, their specific set of goals, for the model of care. That said, we, you know, we would encourage plans to aim high, but there is no requirement to, to, to set the… Laura Zwolinski: The goal at 5 stars. Laura Zwolinski: Let's see, I see another question about… Laura Zwolinski: Matrix. Does the model of care have to be as specific as the matrix? Laura Zwolinski: I'm assuming… Laura Zwolinski: that this question is referring to the variety of options, offered to plans in terms of how, they can submit a matrix document to us this year. Laura Zwolinski: If you've chosen to submit a standalone table of contents for your matrix. Laura Zwolinski: It does not have to be as detailed in terms of all of the language included in the matrix document. However, it should outline each of the elements and factors specifically, and provide the page number that's associated with those Laura Zwolinski: those factors. Shree Patel: Thanks, Laura. Shree Patel: I also want to call to attention, if anyone has any live questions, please feel free to raise your hand. Shree Patel: At this time. Shree Patel: Okay, we can go back to the Q&As. Shree Patel: The next question we have in the queue is, if we don't have great data, even proxy data, for the most vulnerable, can we provide data for the general and explain how we think that the most vulnerable will look different based on our own assumptions? Shree Patel: It is particularly hard for new plans to provide exact data for the most vulnerable subset. Laura Zwolinski: Yeah, thank you for that question. You know, I think as a new plan, which it sounds like you are. Laura Zwolinski: We would want to see some proxy data. Laura Zwolinski: However, you can go ahead and caveat that data. Laura Zwolinski: To identify, you know, why you think that that data, you know, it may not be great, but, we are looking for plans to kind of understand what they expect their membership to be if they're new, and so, I think to, we would recommend to the best of your ability to identify proxy data. Laura Zwolinski: that may, approximate what you anticipate your, most vulnerable population would be, and include that data. And, feel free to include any caveats about that data or footnotes about that data to sort of, you know, just describe what you, you know, you think Laura Zwolinski: You think will happen, in terms of… of the… Laura Zwolinski: Sort of demographic breakdown, and, Laura Zwolinski: sort of conditions and factors that are impacting that particular population. And in terms of renewal plans. Laura Zwolinski: that may, you know, have just become operational, you know, the same is true. If there are certain areas that you need to provide proxy data for, please go ahead and do that, but definitely identify that that is what you're doing and why. Shree Patel: Next question we have is regarding MLC2, Element D, the ICP. Shree Patel: This question notes that we understand the importance or emphasis Shree Patel: on all enrollees having an ICP. However, there is specific person-centered language also listed. When an enrollee declines or refuses to complete an HRA, or was unable to be reached to complete an HRA. Shree Patel: Does a narrative describing that… the decline slash unable to reach suffice slash apply to how NCQA recommends an ICP includes to be person-centered? Enrollee preferences if there is no… no completed HRA for that enrollee? Laura Zwolinski: Yeah. Thank you for this question. Laura Zwolinski: So, in MOC2B, we would, you know, want a description of the process used when an enrollee declines or refuses to complete an HRA, and provisions that are made in those scenarios. Laura Zwolinski: While an HRA requires direct enrollee Laura Zwolinski: Feedback, or responses, or those of a caregiver to be considered complete. Laura Zwolinski: The ICP, may use other sources. Laura Zwolinski: to, other sources may be used to compile an ICP, based on, medical records, claims, other sources to identify an ICP that is Laura Zwolinski: person-specific? Laura Zwolinski: and centered to the degree that that is possible based on those resources available to you. Understanding that, Laura Zwolinski: You know, person-centered may not necessarily, be able to include direct responses from the enrollee if they, you know, are not willing to be involved in that particular process. Laura Zwolinski: You know, we want to encourage plans to make sure that the ICPs are person-specific. Laura Zwolinski: Versus, sort of a, like, a quote-unquote basic plan of care for, for, you know, any Laura Zwolinski: any member that has this particular condition. We do expect that there is, some level of review of resources available to compile to the best Laura Zwolinski: to the degree possible, an ICP that is specific to, that particular enrollee. Madeline Vancott: Alright, we do have a hand up. Laura Zwolinski: Rusty. Madeline Vancott: Kirsten Rhodes? Laura Zwolinski: I'm sorry, Madeline, I wanted to see if CMS had anything that they would like to add there. Madeline Vancott: Apologies. Daniel Lehman: Nothing from me, thank you. Laura Zwolinski: Alright, thank you. Kirsten Rhodes: This is Kirsten. Laura Zwolinski: Hi, good afternoon, Kirsten. We can hear you. Kirsten Rhodes: Okay, yeah, I guess just for clarification on that, because to us it has appeared kind of over the years and ongoing, and we've kind of made some accommodations in how we have addressed that in our model of care, and we just really wanted to be clear on that, that, like, Kirsten Rhodes: you know, we provide support plans or care plans, ICPs, to members, as part of our, Kirsten Rhodes: process, but that is very confusing, or has been historically, if they are getting a goal that they themselves didn't set, and didn't agree with, and that type of thing, and so that's where I… that's where this question kind of depends from. So if there's… they were never able to be reached. Kirsten Rhodes: or they were… have refused to complete that HRA. It just seems very contradictory to have a goal for a member that they don't even participate in creating. Daniel Lehman: Christian, we appreciate your thoughts on this, and we'll take this back and review as we think about this policy going forward. You know, we think there are ways to kind of address that at this point, but we do appreciate hearing from plans on it. Kirsten Rhodes: Thank you for your consideration. Shree Patel: Thank you, Kirsten. Shree Patel: Madeline, it looks like we have another hand raised. AAF7672: Hi, can you hear me? Madeline Vancott: Yes, we can hear you. AAF7672: Great. I just wanted to add to the last statement, just from our perspective as the program AAF7672: manager here. When the nurses have to send these care plans to people They haven't even spoken to. AAF7672: I just think, just to support that position, it is, AAF7672: it's a burden on the staff, and it takes them away from engaging people that want to be engaged, if that… or people that they can reach. They do outreach them, but that administrative burden of creating a care plan for someone that they haven't even spoken to AAF7672: just seems like a futile effort for me. I just think the time could be used more with… AAF7672: continuing to outreach, and getting back to the ones that they couldn't reach, and making sure that HRAs AAF7672: That can be done, can be done, and timely. So I just kind of wanted to add that. Daniel Lehman: Again, we appreciate your thoughts on this. CMS cannot waive, you know, the statutory requirement of having an ICP or the regulations connected to that, but we… AAF7672: Appreciate it. Daniel Lehman: Hearing thoughts from plans. AAF7672: Okay, thank you. Shree Patel: Thank you for that. Shree Patel: Any more hands raised, or additional comments on that before I keep going through the last couple of question and answers? Shree Patel: Alright? Shree Patel: We'll move on to the next question. For MOC 2, Element B, factor 2, describe the process to use… describe process used to stratify enrollees. What would a plan need to include here if it does not stratify its enrollees? Laura Zwolinski: Yeah, thank you for the question. Laura Zwolinski: I think from our perspective, we would expect that a plan has a process to stratify enrollees in order to identify those highest risk, those, you know, lowest risk, and those that, are, in most need of Laura Zwolinski: additional care coordination and management practices. So I'm not sure, Dan, is there anything that you would like to add for this, particular question related to risk stratification? Daniel Lehman: I'm sorry, I'm digesting it, in real time here. Daniel Lehman: I would… I think we would be concerned if there's no stratification of enrollees, Daniel Lehman: And what the justification would be for not stratifying? Daniel Lehman: Yeah, I think we'd like to understand this question a little bit in greater detail, if the… Daniel Lehman: Plan would like to reach out to us at the mailbox. Daniel Lehman: I think we'd wanna… Maybe, have more information. Daniel Lehman: Before we responded. Shree Patel: Thank you for that, Dan. Shree Patel: Next question we have here is for Factor 4. Shree Patel: And Factor 5, they require further clarifications. I'm not sure which this is pertaining to. Shree Patel: However, it asks, are we able to capture all HEDIS, STAR measures, that show members are not receiving their services to meet this requirement, and include what actions are being taken to outreach to care… to close the care gaps? Shree Patel: In addition, during the HRA and ICP process. Shree Patel: Are there steps where we review to determine if a member is seeing their providers and assessing care? Is this process acceptable? Shree Patel: If whoever asked the question would like to please raise their hand, and so we can unmute you for some further clarification. LaTricia Norris- Molina Healthcare: Hi, are you able to hear me? Shree Patel: Yes, we can hear you. LaTricia Norris- Molina Healthcare: Okay, thanks. It was just the follow-up of the question about the member that was not receiving Medicare services. LaTricia Norris- Molina Healthcare: And that was just the clarification that if we use all of the work that we do on members that are… have gaps in care, they're not getting their preventive services, they're not getting their, you know, their measures, they're not following up, you know, after transitions, you know, and all of that work, as well as making sure they're seeing their providers LaTricia Norris- Molina Healthcare: and… Is that acceptable for that measure? Laura Zwolinski: And is this something that would be helpful to submit through the mailbox? Because we have received Laura Zwolinski: A lot of questions specifically about… 4a factor 5. Daniel Lehman: Yeah, I think that'd be great, and we could… we'll certainly… Daniel Lehman: kind of flesh this out in a Q&A document that we'll put out after this call. You know, not right away, obviously, but, you know, I think we'd like to kind of address it there, if we could. And if you could, yeah, please submit it to the mailbox, we'll make sure to Daniel Lehman: To… to fully get to it. LaTricia Norris- Molina Healthcare: Thank you. Shree Patel: Thank you, Dan, for that response. Unfortunately, we are at time, so I will hand it over to Laura for any closing remarks. Laura Zwolinski: Yeah, thank you so much, Sri, and thank you all for your time and attention and your engagement today during this call. I know that there still are a few questions remaining open in Laura Zwolinski: the Q&A, chat box, so we will also take a look at those questions and incorporate Laura Zwolinski: any answers to those questions, along with some of the others that were frequently asked today, into an updated FAQ document that we will post to the SNP approval website. Laura Zwolinski: In the meantime, if you do have any additional questions, please reach out to the CMS DPAP mailbox, and we will work to provide you with answers to those questions as we're able to. Laura Zwolinski: Otherwise, we hope that you have a wonderful afternoon, and please take care. And this concludes our call this afternoon.