Laura Zwolinski: Good afternoon, everyone. Laura Zwolinski: We'll give it a minute or two while we wait for additional attendees to join the session, and we'll begin when we see the attendee count begin to level off. Thank you! Laura Zwolinski: Good afternoon, and welcome to the second SNP Approval Model of Care Pre-Submission Technical Assistance call for contract year 2027 submissions. We look forward to sharing key information with you, and to hearing your questions today. Laura Zwolinski: Next slide. Laura Zwolinski: This slide presents 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 a task lead for SNP Model of Care Review Activities. Laura Zwolinski: I'd also like to introduce Sri Patel, NCQA's Content Analyst, Madeline Vancott, NCQA's Lead Analyst, and Alan Huffman, 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: We'll now hand it over to our colleague at the Centers for Medicare and Medicaid Services, to introduce himself. Laura Zwolinski: Dan, over to you. Daniel Lehman: Thanks, Laura. Daniel Lehman: I want to welcome everyone again for attending our call. Appreciate your attendance. My name is Daniel Lehman, I'm with the Medicare Drug and Health Plan Contract Administration Group, which is in the Center for Medicare, in the Division of Policy Analysis and Planning. Daniel Lehman: And, I am… unfortunately, my colleague Emily Moore, also in DPAP, is unable to join me today, but we, hope to answer all the questions you may have about this year's Daniel Lehman: Model of care submission season. Daniel Lehman: Thanks again. Back to you, Laura. Laura Zwolinski: Thank you, Dan. On behalf of NCQA and CMS, we welcome you to our second SNP Model of Care Pre-Submission Technical Assistance call, and we thank you in advance for your time 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 key updates and reminders for contract year 2027. Laura Zwolinski: And then we will go ahead and open it up for questions. Laura Zwolinski: Please note that the slides for this call were also presented during the first pre-submission TA call. Laura Zwolinski: Where relevant, we will aim to provide additional clarity based on questions received during that call. Laura Zwolinski: Next slide. Laura Zwolinski: Please note that we have muted everyone's lines to reduce audio feedback. 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 through 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, 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: Please be sure to mute yourself once again once finished. Laura Zwolinski: Next slide. Laura Zwolinski: For technical assistance, all training and technical assistance call recordings, slides, and the contract year, or CY2027 Model of Care Matrix and scoring guidelines are posted to the NCQA SNP approval website. 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 CMSNP mailbox noted in the right column of this slide. Laura Zwolinski: And lastly, please review CY 2027 training materials and guidance prior to submitting inquiries. Laura Zwolinski: Next slide. Laura Zwolinski: The SNP model of care approval timeline has shifted for CY2027 compared to prior years. At this point, the CY2027 mock matrix, scoring guidelines, and all training recordings have been made available. Please note that there are four separate trainings this year, one for each MOC standard. Laura Zwolinski: Plans can start uploading CY2027 Model of Care submissions beginning on May 18th. Laura Zwolinski: All submissions are due in HPMS no later than 8 p.m. Eastern Standard Time on Friday, May 29th, 2026. Laura Zwolinski: This change aligns the CMS model of care submission process with the Medicare Advantage statutory bid submission deadline and state Medicaid agency contracting processes. Beginning this year and moving forward. Laura Zwolinski: The mock submission deadline will occur on 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 to CMS on Monday, June 1st. Laura Zwolinski: Upon review of the models of care, 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, 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: CURE submissions are due in HPMS by 8pm Eastern 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 model of care submissions. Laura Zwolinski: Again, all submissions must be uploaded in HPMS by 8pm Eastern Time on May 29th. Laura Zwolinski: Please upload only two documents to HPMS, the Model of Care Narrative and the associated matrix. These are the only documents NCQA downloads and reviews. We do not download or review any other documents or attachments. So please make sure that all information necessary for evaluation Laura Zwolinski: is embedded directly within the appropriate location in the mock, or included as appendices at the end of the document. Laura Zwolinski: To address questions raised during the last TA call, we are sharing additional information regarding the matrix. Laura Zwolinski: Given updates made to the matrix format this year, SNPs have flexibility in how they identify the location of information within their model of care. Laura Zwolinski: First, SNPs may embed a table of contents within the matrix that lists the content description of the molecular element and factor with the corresponding page numbers, and this is the preferred option. Laura Zwolinski: Second, SNPs may convert the model of care from the updated matrix into a table format and include the associated page number for each element and factor. Laura Zwolinski: Third, SNPs may indicate the location of each model of care element and factor by listing the associated page numbers next to the text description included in the matrix. Laura Zwolinski: And regardless of these options, the plan must also include in the matrix. Laura Zwolinski: the SNP contact name, SNP contact… contract number, excuse me, and a list of all affiliated contract numbers using a similar model of care. Laura Zwolinski: In terms of format and structure of the MOC, 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 an efficient review process and aligns your model of care with the most current guidance. Laura Zwolinski: We thank you in advance for your cooperation on this item. Laura Zwolinski: And lastly, please be sure not to include any protected health information or personally identifiable information in your model of care. Laura Zwolinski: We strongly advise SNPs to thoughtfully consider your model of care. Laura Zwolinski: Each submission year is an opportunity to think through and improve processes. 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 capsule Laura Zwolinski: Capture process updates and changes. Laura Zwolinski: Next slide, please. Laura Zwolinski: We're now going to review key updates and reminders for CY2027. Laura Zwolinski: Next slide. Laura Zwolinski: In terms of high-level changes made for CY2027, substantive changes have been made to element and factor requirements this year to reflect revisions to the matrix, which CMS released earlier this year. Laura Zwolinski: In addition, the CY2027 scoring guidelines were updated to align with this new matrix. Laura Zwolinski: To ensure that you understand these revisions and the corresponding changes you'll need to address in your model of care. Laura Zwolinski: We encourage you to review this year's matrix and scoring guidelines thoroughly, as well as to listen to all training recordings. Laura Zwolinski: Please also make sure that the 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. The purpose is to capture key overall changes. Laura Zwolinski: Please ensure that you review the matrix and scoring guidelines and listen to training recordings to 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 had substantive content and factor order changes this year. Laura Zwolinski: 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 included 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, for instance, CSNP, DSNP, or ISNP, Laura Zwolinski: The SNP detail, for example, chronic lung disorder, if you're a CSNP, or hybrid institutional if you're an ISNP. Laura Zwolinski: DSNPs must also specify the intended integration level. For example, fully integrated, highly integrated, or coordination only, and they must also describe the anticipated eligibility categories. Laura Zwolinski: For instance, qualified Medicare beneficiary only, or specified low-income Medicare beneficiary only, covered by the model of care being submitted. Laura Zwolinski: Lastly, all SNPs must specify whether the submission is an initial, renewal, or off-cycle submission. Laura Zwolinski: Next slide. Laura Zwolinski: The orders of factors 2 through 4 shifted, and all of these factors now require information for both the general and the most vulnerable populations. Laura Zwolinski: For Factor 2, SNPs must provide demographic data and details for both populations. 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. Laura Zwolinski: As well as to describe 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. For example, health literacy, poor socioeconomic status, housing, food, and transportation insecurities, etc, and describe actions taken to address these needs. Laura Zwolinski: For all of these factors, please be sure to differentiate between the general and most vulnerable populations. Laura Zwolinski: SNPs reviewing their, excuse me, SNPs renewing their contracts after year two of operations must provide their own historical data instead of other local, national, 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 January 1st of this year. Laura Zwolinski: or a renewal plan that has not been operational for 2 years yet, you may include proxy data. In these cases, please 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. 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 demographic information, identifying each service area in the target population, for instance, county or state, and including a breakdown of demographic categories, such as age, sex, language spoken, and education for each. Laura Zwolinski: Please ensure the demographic details for both the general and most vulnerable populations are included, that all information is specific to the population served, and that it is provided for all service areas. Laura Zwolinski: Based on questions received during the first TA call, we wanted to clarify a few things related to MOC1A. Laura Zwolinski: First, while some plans provide membership data and information at the county level, plans are not required to include demographic details at this level of granularity. Laura Zwolinski: Please note that if the plan operates in multiple states, data and information must be provided for all states for both the general and most vulnerable populations. Laura Zwolinski: Second, there were questions about whether the provision of ethnicity data is required for CY2027. Laura Zwolinski: We'd like to clarify that while ethnicity is used as an example of demographic information in the matrix, CMS does not require or request any information related to enrollee race or ethnicity. Plans will not be scored down for providing or not providing data on race or ethnicity. Laura Zwolinski: Lastly for this slide, we want to note that some plans include a narrative of demographic information rather than a table. This approach is also acceptable. However, if using this format. Laura Zwolinski: The same level of detail is expected. Laura Zwolinski: Next slide, please. Laura Zwolinski: For MOC 1B, which is the services for the most vulnerable enrollees, this element also had some substantive content and factor ordering 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 new factors were included this year, which we'll review on the next slide. Laura Zwolinski: For Factor 1, Laura Zwolinski: Please be sure to provide a detailed and specific list of the inclusion criteria used to determine the most vulnerable population, as well as 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. Laura Zwolinski: Factor 2 is new this year and focuses on the care management practices employed for and the benefits tailored to the most vulnerable enrollees. Laura Zwolinski: To meet this factor, plans should detail the tailored services, resources, and additional benefits for the most vulnerable enrollees. Laura Zwolinski: We understand that plans may not necessarily offer services or benefits exclusive to the most vulnerable population. Laura Zwolinski: In this case, plans should acknowledge this and can identify services and benefits that may not be exclusive to the most vulnerable population, but that would be highly beneficial or used more frequently by that population. For instance, transportation services, healthy food and produce benefits, special social services, or advanced care planning. Laura Zwolinski: Care management practices may entail more frequent connection with the enrollee by the care manager based on the enrollee's higher acuity, leading to more frequent ICP updates and connection with the ICT. Laura Zwolinski: Lastly, please be sure to 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 their caregivers, as well as how they support and or 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 plans earned 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: We'd like to clarify that CMS and NCQA do not narrowly define the term established partnerships. That is, there is no requirement for a formal agreement to be in place between the plan and the community partner in order to include them in the response to this factor. The presence of ongoing functional collaboration is sufficient to be considered a community partner. Laura Zwolinski: The plan may use discretion in listing the partnerships that are critical in meeting the needs of the most vulnerable enrollees. Laura Zwolinski: Lastly, Factor 4 is also new this year. Laura Zwolinski: It requires a plan to explain any challenges associated with establishing community organization partnerships that impact the ability to connect enrollees to specific services. Laura Zwolinski: As part of this response, SNPs must describe potential mitigation strategies and solutions. Laura Zwolinski: We'd like to emphasize that MOC1A and B were some of the most frequently failed elements last year. That is, not meeting these elements was a common reason that plans are required to cure. Laura Zwolinski: Given this, and in conjunction with the changes made for these elements this year, we are emphasizing 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. For MOC 2A, which is about SNP 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 from 7 to 6. Shree Patel: 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 function, plans are also required to describe their disaster preparedness Shree Patel: And recovery plans in event of an emergency. Shree Patel: We also have some reminders for Factor 4. Shree Patel: Renewal submissions. Shree Patel: You must include a sample-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 the training content. Do not provide general information, such as a table of contents or a bulleted lists of topics without substantive details. Shree Patel: Next slide. Shree Patel: For MOC2B, the Health Race 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. Shree Patel: Please describe the administrative process completely, addressing the who, what, where, when, how, and the methodology used to administer the HRA. Shree Patel: This year, a number of new requirements were specified, and the need to be addressed to… in order to earn credit for Factor 1. Shree Patel: First, plans must summarize and describe the HRA tool or tools that they are using. Shree Patel: To meet this requirement, plans must address how the HRA tool or tools specifically assess the medical, functional, cognitive, psychosocial, and mental health needs of enrollees to demonstrate that the tool is comprehensive. Shree Patel: This goes beyond a general statement that the HRA tool assesses these five domains. Plans can meet this component Shree Patel: of the factor in a variety of ways. For instance, providing a copy of the HRA tool or tools within the response to this factor, or as an appendix to the MOC, and identify how the tools assess these five domains. Shree Patel: Including an excerpt of questions from the HRA tools specific to the five domains. And lastly, identifying the HRA tools by name and describing how each one includes items that assesses these five domains. Shree Patel: SNPs must also specify the timing of the initial HRA and annual reassessments, which must align with the regulations. That is, within 90 days of effective enrollment date for new enrollees and annually for existing members. Shree Patel: Most plans are already providing this information. However, please be sure to if you are not already. Shree Patel: SNPs need to 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. Shree Patel: 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 the NHRA, 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 also 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. Shree Patel: As well as provide the inclusion criteria and acuity level for each tier to earn credit. The acuity level reflects the anticipated outreach frequency for each risk tier. Shree Patel: In addition, the response 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 the 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, Pryor's Factor 5, which was about addressing health concerns, and 6, which was about care coordination activities, were combined into a new Factor 5, reducing the total number of factors in this element from 6 to 5. Shree Patel: Factor 3 requires that SNPs 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 the reporting, tracking, and responsible staff. Shree Patel: In addition, for CY2027, SNPs also need to describe any follow-up communications with enrollee or caregivers during the face-to-face encounter verification process, if applicable. Shree Patel: Lastly, Factor V requires that SNPs describe how they ensure that appropriate follow-up, referrals, and scheduling for needed care services are completed following the face-to-face encounter. Shree Patel: Next slide. Shree Patel: For MOC2D, which is about the ICP, Shree Patel: Priors, factors 2 and 3 were combined, reducing the total 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 that are stratified as medium or high risk. Shree Patel: For Factor 2, SNPs must describe how they develop an ICP for each enrollee and 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. Shree Patel: The MOC must also include a description of the frequency at which SNP personnel review, update, and or modify the ICP based on evaluation of enrollee goals, as prioritized by the enrollee. Changes in healthcare needs or status. Shree Patel: or the availability of more recent HRA information. Shree Patel: There are a few new requirements specified for this year. First, SNPs must specify the timing of ICP development, which must comply with the regulations. That is, within 90 days of conducting the initial HRA, or 90 days after the 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 enrollee and or their caregivers or representatives are involved and participate in the ICP development process. Shree Patel: Also newly specified for this year. Shree Patel: Also newly specified for this year, the plan must describe how the SNP addresses challenges associated with the enrollees who declined to participate in the ICP process or who are unable to be reached, and how it documents the attempts to contact the enrollee or the enrollee's refusal to participate. Shree Patel: Lastly, we want to draw your attention to the new DSNP-specific requirement for this factor. This component of Factor 2 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 Shree Patel: And mental, behavioral health services. Shree Patel: DSNPs need to address this item in addition to the others noted in this slide to earn credit for Factor 2. Shree Patel: Next slide. Shree Patel: For Factor 3, the SNP must describe how the ICP is maintained and updated based on changes in health status or care transitions. Shree Patel: And new for contract year 2027, SNPs must address where ICP is documented and stored. Shree Patel: Specify how the enrollees and or their caregivers are provided with copies of or electronic access to their ICP, Shree Patel: and detail how the plan ensures that the ICT, provider network, appropriate stakeholders, and enrollees and or their caregivers have access Shree Patel: to the ICP, as well as the delivery mechanism for providing the ICP to these stakeholders. For example, this can include mail, fax, or a patient portal, etc. Shree Patel: Next slide. Shree Patel: For MOC2E, the Interdisciplinary Care Team, or ICT, element has also had a few updates this year. Shree Patel: For Factor 1, plans must describe 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 Shree Patel: to participate as active ICT members, and provides them with needed resources. Shree Patel: Next slide. Shree Patel: Newly emphasized and clarified for this year, Factor 3. SNPs must explain how they analyze enrollee needs and outcome data to 1 Shree Patel: Evaluate and continually manage and improve the health status of SNP enrollees, and two, implement and manage changes and or adjustments to the ICT composition as needed. Shree Patel: For Factor 3… for Factor 4, please note that the new DSNP-specific requirement to explain how the ICT coordinates with Medicaid providers when there are needed Medicaid-covered medical or social services that the plan does not cover if it is applicable. Shree Patel: Next slide. Shree Patel: MOC2F is about care transition protocols. Shree Patel: 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. First, SNPs must explain the process used for both planned and unplanned transitions. Shree Patel: For plan transitions, the MOC must describe the steps taken place before, during, and after the transition occurs. Shree Patel: For unplanned transitions of care, the MOC must describe the steps taken during, if known, and after the transition occurs. Shree Patel: Second, DSNPs must also 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: For instance, if this looks like hard copies, electronic access, or an access via a patient portal, etc. Shree Patel: Next slide. Shree Patel: Again, 3 new requirements specific to DSNPs were added to MOC2 for CY2027. Shree Patel: DSNPs must address these requirements to earn credit for the associated factor. Shree Patel: TSNPs must fulfill these requirements in addition to the other requirements of the specified factor to earn credit. Shree Patel: The DSNP-specific requirements do not impact the total number of factors evaluated for this element. Shree Patel: Next slide. Shree Patel: Now we'll move on to MOC3. Shree Patel: For MOC3A, specialized expertise of the provider network. Shree Patel: The order of prior factors 3 and 4 were switched. Shree Patel: For Factor 3, which is about provider collaboration with the ICT, SNPs must 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. Shree Patel: The intent is to describe how information is shared amongst providers, the ICT, and with enrollees about care needs and preferences, and how care is coordinated so that enrollees receive services in a timely and effective way. Shree Patel: While CMS recognizes that plans cannot control the specific provider-enrollee interaction as a part of direct care, plans should support and help support the infrastructure needed so that there is coordination between the ICT and updates made to the ICP that reflect services rendered and identified needs. Shree Patel: For Factor 4, please don't forget to specify the frequency for updating provider information in addition to the general process for doing so. Shree Patel: 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 in this element from 4 to 3. Shree Patel: In addition, SNPs are now required to do the following in 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, detailed oversight of enrollees for whom clinical practice guidelines were modified. Shree Patel: And lastly, for Factor 3, detail how care transition protocols are used both internally and by contracted providers to maintain the continuity of care. Shree Patel: The new piece for this factor this year is that plans must explain how it ensures that the care transition protocols are used internally, in addition to doing so for providers. Shree Patel: Next slide. Shree Patel: MOC 3C is about MOC training for provider network staff. Shree Patel: We have a few key reminders for Factor 1. Shree Patel: Please be sure to describe the implementation of the provider training and demonstrate evidence that MOC training is made available to all appropriate in-network and out-of-network providers. Shree Patel: For renewal submissions, please 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. This is a shift in focus over the last year, when the 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'll hand it back over to Laura to review MOC4. Shree Patel: Next slide. Laura Zwolinski: Thank you, Sri. Laura Zwolinski: For MOC 4A, the MOC Quality Performance Improvement Plan, we wanted to note two things. 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. 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 to identify and connect with these enrollees. Laura Zwolinski: 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: A variety of questions were submitted for this new factor during the last TA call. Laura Zwolinski: We'd like to take the time to provide responses to some of those questions here. Laura Zwolinski: First, what expectations does CMS have for plans to address this new factor, and what actions are sufficient to meet the requirement to connect with these enrollees? Laura Zwolinski: We'd like to clarify that CMS is not prescriptive in how SNPs should structure their processes for capturing enrollees who did not receive any Medicare-covered services during a defined period. Laura Zwolinski: The plan must describe how it identifies these members so that the SNP can implement processes to encourage them to obtain primary and preventive care services as warranted. Laura Zwolinski: SNPs are already required to have at least one face-to-face encounter for the delivery of healthcare or care management or care coordination services. Further, there are best practices for annual wellness visits and other preventive care services, such as immunizations and cancer screenings, on an annual or semi-annual basis. Laura Zwolinski: If special needs individuals are not receiving Medicare-covered services, this may be due to barriers in accessing care, which may exacerbate poor health outcomes. Laura Zwolinski: CMS is not prescriptive in terms of the actions taken by the SNP to connect with these enrollees once they have been identified. However, HRA or ICP reassessment, outreach, or care management engagement are acceptable. Laura Zwolinski: The next question was, how does CMS define no-covered Medicare services? Does this include Part A and B claims only? Laura Zwolinski: Or, should encounter data, preventive services, or supplemental benefits be included? Laura Zwolinski: Should Part D utilization be included or excluded from this determination? Laura Zwolinski: For the purposes of responding to this factor, Medicare-covered services include coverage of Parts A, B, and D. Laura Zwolinski: In addition, services can also include Part C supplemental benefits and SNP care management service requirements. Laura Zwolinski: The next question… What timeframes does CMS consider reasonable for the defined period of time? Laura Zwolinski: Is a rolling review period acceptable, or should plans use fixed calendar intervals? Laura Zwolinski: Please note that CMS is not prescriptive in how SNPs should structure their processes for capturing enrollees who did not receive any Medicare services during a defined time period. Laura Zwolinski: This includes whether reviews are performed at fixed intervals or on a rolling basis. However, CMS does strongly encourage plans to establish review processes performed at least annually, if not more frequently. Laura Zwolinski: And lastly, does CMS expect different monitoring periods for new versus established enrollees, or by SNP type? Laura Zwolinski: And while there may be circumstances in which a SNP would establish tracking processes that differ based on enrollee characteristics. Laura Zwolinski: Plans are still expected to create processes to identify any enrollee, regardless of circumstances, who has received no Medicare-covered services. Laura Zwolinski: Next slide. Laura Zwolinski: For MOC 4B measurable goals, factors 4, the determination of goals met or not met, and factor 5, actions taken when goals are not met from last year, were combined into a single factor this year. Laura Zwolinski: And that reduced the number of factors for this element 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. Laura Zwolinski: And enhancing care transitions across providers and settings. Laura Zwolinski: Goals must be measurable and specific. Laura Zwolinski: SNPs must include specific data sources, benchmarks. Laura Zwolinski: 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. Laura Zwolinski: 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 measures, goals for the new model of care. For example, these could include ensuring appropriate utilization of services for chronic conditions and preventive health services. Laura Zwolinski: Again, 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 goals. Again, do not list goals as TBD. Laura Zwolinski: These goals are specific to the new model of care, as a reminder. Laura Zwolinski: Factor 4 requires renewal plans to include a determination of whether each goal of the previously approved model of care was met or not met. Laura Zwolinski: And require 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, for example, you are an initial submission. Laura Zwolinski: or a renewal submission that just began operations in January of this year. Laura Zwolinski: Please make sure to specify this reason in your response. Laura Zwolinski: In addition, please note that renewal models of care must 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: Next slide. Laura Zwolinski: So this table illustrates how plans can address the requirements specified for overall model of care performance goals for Factor 1, and that's for the new goals, and for Factor 4, which would be for the goals of the previously approved model of care. Laura Zwolinski: The first 5 columns, shaded in blue here, represent 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. Laura Zwolinski: being submitted for approval. To meet Factor 1, the table provides a description of each goal, the quantified goal itself. Laura Zwolinski: The current benchmark The data sources used to collect information required to analyze school performance. Laura Zwolinski: And it also specifies the measurement frequency. Laura Zwolinski: The specific goals in this example include access and affordability goals. Laura Zwolinski: In addition to HRA, ICP, and ICT completion goals. Laura Zwolinski: Please note that this is not an exhaustive list of goals, and the goals for your plan will likely include additional performance goals, such as care transition or member satisfaction goals. Laura Zwolinski: I'd like to point out 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 the 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 here, have been added to provide the quantified goal results. A designation of whether the goal was met or not met. Laura Zwolinski: And when and how frequently the coal will be remeasured. Laura Zwolinski: SNPs must capture information for all column topics in this table to meet Factor 4. Laura Zwolinski: Please note that beyond the table itself, renewal plans also need to provide an action plan for goals not met, and address how goals will be revised and remeasured. Laura Zwolinski: We recommend that plans use a table to provide information for these factors. However, a narrative approach is acceptable, given the necessary details are included. Laura Zwolinski: For ease of illustration, we did want to note that this table assumes identical goals for the previously approved and new model of care. 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: Also, please note that for Factor 4, renewal models of care must include the results and determinations of met or not met for both its overall mock performance goals and its health outcome goals. So those would be… those health outcome goals would be the goals that are included under Factor 2. Laura Zwolinski: Next slide, please. Laura Zwolinski: For MOC4C, measuring patient experience of care. Laura Zwolinski: Prior Factors 1, which are about the survey description, and two, the survey rationale, were combined under Factor 1 this year. Laura Zwolinski: SNPs are also, they also now need to address the following additional requirements for CY2027. Laura Zwolinski: For Factor 2, describe the methodology, including 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. Laura Zwolinski: 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: And for Factor 4, describe the process used to address issues identified through survey responses and the steps taken to address these issues. Laura Zwolinski: Next slide. Laura Zwolinski: Finally, last year's Element 4D, which was about ongoing performance improvement evaluation of the model of care, was deleted, shifting prior element E, which was about dissemination of model of care quality performance results, up to new Element D this year. 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 or stored. 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: So we did want to share a few reminders. Recordings and slides for all training sessions are posted to the SNP Approval website under the Resources section. Laura Zwolinski: This is also where training slides and recordings from the pre-submission TA calls will be posted. Laura Zwolinski: We anticipate posting an updated version of the FAQ that considers questions received during this year's TA calls to the website soon. Laura Zwolinski: The Cure TA call is scheduled from 2 to 4 p.m. Eastern Standard Time on August 4th, 2026. Laura Zwolinski: 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 that session. Laura Zwolinski: In addition, the recordings from all TA calls will be made available to plans via the SNP approval website. Laura Zwolinski: Next slide, please. Laura Zwolinski: We'd like to take, to note here that we have included a short post-training survey for each of the model of care trainings. Laura Zwolinski: 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. Laura Zwolinski: Results and comments will be used to improve future training sessions, and we do thank you in advance for taking the time to complete these surveys and provide us with any feedback that you have. Laura Zwolinski: Next slide, please. Laura Zwolinski: And so that concludes our planned updates, clarifications, and points of emphasis for CY2027 for today's TA call. And so we'll now open it up for any questions. Again, feel free to submit questions via the Q&A feature. Laura Zwolinski: Or raise your hand to ask your question live. Shree Patel: I'll give it another minute to see if anyone has any immediate questions, and raises their hand. If not, we can jump into the Q&A. Laura Zwolinski: Sounds good. Thank you, Sri. Shree Patel: Okay, we can go ahead and get started with this first question here. It's regarding MOC2A, factor 2. Shree Patel: The scoring guidelines ask for an organizational chart and staff responsibilities and job titles. Is it sufficient to include department names or role names and refer to our table in MOC 2A Factor 1 for details on staff responsibilities? Laura Zwolinski: Thank you for this question. Appreciate the clarification. Laura Zwolinski: So, the… Laura Zwolinski: Organizational chart itself, it's fine if you include role names only, you do not need to identify anyone by name. Laura Zwolinski: In addition, in terms of the staff responsibilities piece, yes, it is, certainly appropriate to go ahead and refer us to the information that you've provided under the previous factor to address that component of Factor II under 2A. Laura Zwolinski: Thank you for that question. Shree Patel: Thank you, Laura. Shree Patel: Alright, we can move on to the next question. Shree Patel: It is pertaining to MOC2A factor 4. Is it sufficient to provide training slides to our current model of care? Or does the content need to already be updated to the new model of care? Laura Zwolinski: Thank you for the question. Laura Zwolinski: To the extent possible. Laura Zwolinski: it'd be ideal if training slides are updated based on the new model of care. However, we understand that there are some administrative limitations around that, and burden, and so, Laura Zwolinski: it is… Laura Zwolinski: okay and acceptable to go ahead and include training slides that, you know, perhaps you used this past year. Laura Zwolinski: Understanding that… The information would be updated to capture any new regulations or guidelines or processes. Laura Zwolinski: within your particular SNP prior to the time at which you were to release training to either MOC staff or providers. Shree Patel: Thank you, Laura. Shree Patel: Okay, next question. Shree Patel: What is expected in terms of a plan's incorporation of provider satisfaction in the QI process? It appears to be a new requirement for MOC4 Element A. Daniel Lehman: Laura, I can jump in here, and please let me know if you have other thoughts as well. So I think we are sort of flexible here in terms of the type of information that the plan can provide. So, I mean, it can be… Daniel Lehman: Around the number of facets as far as provider satisfa… Excuse me, satisfaction. That's the word I was trying to say. Daniel Lehman: So, you know, we think there are… Daniel Lehman: a number of elements here that could be captured, that the plan could provide. We are not necessarily Daniel Lehman: Prescriptive around one particular mechanism. Daniel Lehman: And I think our approach to reviewing that information will be, you know, in a similar manner, where we're not necessarily expecting Daniel Lehman: plans to provide X. Daniel Lehman: In this particular area. Daniel Lehman: I don't know if NCQA has any additional, thoughts on that? Laura Zwolinski: I think… thank you for that, Dan, and for this question. Laura Zwolinski: I… not necessarily any additional thoughts, but just… Laura Zwolinski: just echoing that, CMS and NCR are not prescriptive here, and there is no requirement to implement a formal provider satisfaction survey, or any particular formal, Laura Zwolinski: item related to this piece. You know, we really are just looking to you to share with us what your processes are in terms of Laura Zwolinski: Of capturing results from these, surveys, and sort of making them actionable. Shree Patel: Thank you, Dan and Laura. Shree Patel: Next question we have up here is about MOC 3C, Factor 1. When providing sample training slides, does CMS expect certain sections to be representative, such as introductory content, required training topics, summaries, or evaluation components? Laura Zwolinski: Thank you for this question. Laura Zwolinski: again, CMS and NCQR are not prescriptive about the information that you provide related to training materials, given that for the model of care provider training. Laura Zwolinski: That some of the information and training materials shared include specific information geared to clinicians and providers. Laura Zwolinski: To support them in fulfilling the, goals of the model of care. For instance, most often, we do see plans responding to this particular factor include clinician-directed information related to the HRA, care coordination. Laura Zwolinski: the ICP, the ICT, care transition, so that's something that we do see quite often, and we do look for some component of Laura Zwolinski: Clinician or provider-specific instruction. Laura Zwolinski: That said, there's no requirement that Laura Zwolinski: Plans need to represent an introduction, or a conclusion, or an evaluation component. Laura Zwolinski: That said, some plans do opt to describe what their process is around evaluation on content from the training, but this is not required for purposes of the model of care. Shree Patel: Thank you, Laura. Shree Patel: Next question is, is annual review a sufficient timeframe or frequency of review for some quality measures, or will plans be marked down if progress is not assessed more frequently? Shree Patel: To my knowledge, annual review is sufficient, but Laura or Dan, you can jump in if I'm misinterpreting that. Daniel Lehman: So this is Dan. The only thing I will say is that, you know, for CSNPs, obviously you're submitting annually. Daniel Lehman: So I think it changes the dynamic of how you're doing that, quality measure review process. Daniel Lehman: I'm not sure the annual Daniel Lehman: Review would necessarily have to occur if you are… Daniel Lehman: On a different timeline, as far as your, sort of, quote-unquote period of performance for your mock? Daniel Lehman: I think, you know, however the plant sort of defines in those circumstances. Daniel Lehman: As long as there's some check-in on, you know, kind of the quality review. Daniel Lehman: Obviously, NCQA, please let me know if you have additional thoughts. Laura Zwolinski: Nothing else to add there, Dan. I was about to share sort of the same piece around, sort of the annual reporting requirement for CSNPs, but there's no required Laura Zwolinski: required time frame. Laura Zwolinski: at which… Plans need to, sort of assess and capture… Laura Zwolinski: information related to the goals that they set for themselves. That said, we… we do expect that plans sort of have a holistic array of goals that are reasonable, for themselves, that, either, would, Laura Zwolinski: Sort of showcase improvement over time, or showcase, you know, maintaining sort of a… Laura Zwolinski: high performance over time. But that said, there's no… there's no timing requirement there. Shree Patel: Thank you. Shree Patel: Next question is pertaining to MOC 4B, Factor 1. This question asks. Shree Patel: Does CMS expect the exact column to be dis… Shree Patel: discussed to be used, or is flexibility allowed if all required elements are captured? Could you also clarify the distinction between a benchmark and a goal, and what CMS expects to see for each? Laura Zwolinski: Yeah, thank you for this question. Laura Zwolinski: No, plans are not required to use the exact columns that were shared in the example provided. Laura Zwolinski: To showcase, the components required for Laura Zwolinski: the overall goals of the model of care and the enrollee health outcome goals. It's up to the discretion of the plan on how they'd like to present that information in their model of care. Laura Zwolinski: Most plans do provide a table that captures those pieces. Laura Zwolinski: Of information. However, again, some plans do opt to provide those details in a narrative format. Laura Zwolinski: In which case, that is also acceptable. Reviewers will just be looking for the same details that were noted previously. Laura Zwolinski: In terms of, the piece of the question about clarifying the distinction between the benchmark and the goal. Laura Zwolinski: So… Laura Zwolinski: The benchmark included for that ex… so, the benchmark would sort of represent the plan's prior performance, if they were a renewal plan, or it… it could present average performance if they are a new plan. Laura Zwolinski: Whereas the goal is what you are… are trying to achieve for this particular model of care approval cycle. Laura Zwolinski: Anything to add from the NCQA team on that? Or, or Dan from CMOS? Daniel Lehman: Nothing in addition for me, thank you. Shree Patel: Nothing for me either. Thank you, Laura. Shree Patel: Next question we have is pertaining to MOC 4A, Factor 5, the identification of enrollees with no covered Medicare services. Shree Patel: Tina asks. Shree Patel: What actions are sufficient to meet the requirement for outreach? Is there a minimum number of outreach attempts required, and can that mechanism of outreach be telephone, text, mailer, etc? Shree Patel: Oh. Daniel Lehman: Yeah, I'll jump in this one. This is Dan. Daniel Lehman: So I don't think this… so the intent here is not… Daniel Lehman: the same as… you may be familiar with the process for, HRA reporting and some of the requirements around how Daniel Lehman: one, and, reaches out to folks, and the requirements around that. I think there's a broad array of, Daniel Lehman: options plans would have here as far as outreach, for Mach 4A5, and we are not prescriptive as far as the number of outreach attempts. Again, I think this is more about, sort of. Daniel Lehman: tracking of Medicare services, at… Daniel Lehman: being aware of access to services for members, things of that nature. But I don't think we are necessarily prescriptive around Daniel Lehman: Outreach for members who are, identified. Daniel Lehman: Ncqa, any additional thoughts? Laura Zwolinski: Nothing to add, Dan, thank you. Shree Patel: Alright, next question is, if goals are met, can plans maintain the same standard for future years to maintain desired performance, or are plans required to increase targets? Laura Zwolinski: Thank you for the question. Laura Zwolinski: So CMS or NCQA are not prescriptive on setting goals to any particular level of performance, and that's with the exception Laura Zwolinski: of the requirement to set the HRA, ICP, and ICT goals to 100%. Laura Zwolinski: For goals beyond these three, plans are encouraged to set goals that would demonstrate improved performance or maintain past high performance. Laura Zwolinski: But regardless of what goals are used, plans do need to provide quantifiable data to demonstrate current performance and evaluate whether the goal is met or not met. Laura Zwolinski: Dan or NCQA team, anything to add there? Daniel Lehman: No, I agree with that, thank you. Shree Patel: Hey, Laura. Shree Patel: Next question, also pertaining to MOC4, is, are benchmarks prior year data points or averages, by your definition, required to be included in MOC 4B? Shree Patel: We have always defined our goal slash target as our benchmark. Is this okay? Laura Zwolinski: Thank you for the question. Laura Zwolinski: So… I think typically… so, we would say yes to include either prior year's benchmark. Laura Zwolinski: Or an average, in addition to your current goal. Laura Zwolinski: And that's for, the goals of the new model of care for MOC4B, Factors 1 and Factors 2. So the overall goals of the model of care and for the health enrollee outcome. Shree Patel: Thank you, Laura. Shree Patel: Next question we have here is, for the MOC1 vulnerable population, should the plan consider breaking it down by county? We are an urban plan that only provides coverage in a large city made up of 5 counties. Laura Zwolinski: Thank you for the question. Laura Zwolinski: So… I think… NCQA and CMS believe that plans are in the best position to determine how Laura Zwolinski: it makes most sense to provide information about the most vulnerable pop… about your most vulnerable population and your population in general. Again, there is no requirement to provide information Laura Zwolinski: Particularly at a county level. However, plans do choose to do that often. Laura Zwolinski: But there… there's no specific requirement. Laura Zwolinski: And, we would leave that to the discretion of the plan. Shree Patel: Thank you, Laura. And that coincides with a different question that we had, which was, for vulnerable and least vulnerable populations, is it best to split them by county? Shree Patel: And it's seemingly, from Laura's guidance, it is up to the discretion of the plan. Shree Patel: Do we have any more questions that anyone would like to do with raised hands? We can answer them live here. Madeline can unmute you. Madeline Vancott: Alright, we've got a raised hand from Jessica Sabona. Madeline Vancott: Jessica, you should now be able to unmute. Jessica Sibona: Hi, thank you, can you hear me? Madeline Vancott: Yes, we can hear you. Jessica Sibona: Great, thanks. I can hear myself a couple times. Just quickly wanted to ask if you have feedback about, most vulnerable populations being of a certain size. Jessica Sibona: If you're a small plan with maybe a few hundred members, do you have any guidance about how large that population should be? Laura Zwolinski: Thank you for your question, Jessica. Laura Zwolinski: So we don't have any sort of, minimum Laura Zwolinski: count of what the membership needs to be to provide us with information. I think if you are a renewing plan that's been in operation for Laura Zwolinski: at least 2 years. We would expect you to provide to us the information that you have on your most vulnerable membership. Laura Zwolinski: That said, if you still don't have any members that kind of fit that category, or you have very limited members, you can provide to us proxy data. Laura Zwolinski: In that instance. However, please be sure to preface the, sort of, the limitation around your data. Laura Zwolinski: If that is the case, indicating why you're using the data that you… you do end up, including. But there's no… there's no, sort of lower limit on what is appropriate for purposes of the model of care to report on your most, vulnerable Laura Zwolinski: population, and we've certainly had models of care come through where there's, you know, less than 10 members who are part of the most vulnerable population, and plans have provided information on that. So, no lower bounds there. Laura Zwolinski: Dan, our NCQA team, anything you want to add there? And does that answer the question, Jessica? Jessica Sibona: Yeah, that's very helpful, thank you. Laura Zwolinski: Sure. Daniel Lehman: Nothing else from me on that one, Laura, thank you. Shree Patel: Thank you, Laura. Thank you, Dan, and thank you, Jessica, for your question. Shree Patel: Any more raised hands before we move back to Q&A? Shree Patel: Alright, it looks like we have actually completed all of our Q&A answers. Shree Patel: Please submit any more Q&A questions that you have at this time. Shree Patel: Okay, we have one here. The question is, we use standard benchmarks, such as the CMS 4-star cut point, and set these benchmarks as our goals. Is this sufficient? Laura Zwolinski: Yes, thank you for the question. That is sufficient. Leave it to the discretion of the plan, how they complete their goal setting based on any benchmark data that they have available to them, but that is appropriate. Laura Zwolinski: What I will share, and clarify is that the only instance in which this is not the case is for the care coordination required goals for the HRA, ICP, and ICT. Laura Zwolinski: Those goals must be set to 100%, or to, 5 stars. Shree Patel: Thank you, Laura. Shree Patel: Alright, and it looks like we have, a follow-up question for what we just discussed. Shree Patel: And the question is, if the stars, benchmarks, or measures are removed, will we have to make edits? Shree Patel: I think, that may need a little bit of further clarification if, whoever asked that question would like to raise their hand. Madeline Vancott: Okay, we have a hand up. Madeline Vancott: Now tell me you should now be able to unmute. METELMI: Yes, no, I was just curious, because, you know, ideally, if we set our mock for, like, 3 years, if these, like, measures go away, and, like, the benchmark isn't there anymore, like, what would we… METELMI: like we do. Like, do we just still use it as is, or would we have to make edits to, like, show that we're using a new benchmark now? Daniel Lehman: This is Dan, and NCQA can… you can let me know if you agree or disagree, but I think, you know, Daniel Lehman: Plans likely have… A number of, Daniel Lehman: measures or quality guideposts incorporated, and I think, you know, when you renew your mock the next time. Daniel Lehman: You can make note that CMS discontinued a measure Daniel Lehman: And why… obviously, why it would be difficult to sort of continue, using that as a… Daniel Lehman: As a marker of quality, Daniel Lehman: Ncqa, let me know if you, have any additional thoughts. Laura Zwolinski: Yeah, I would agree that that's something that can be addressed in the subsequent submission of Laura Zwolinski: the, SNPs model of care. Laura Zwolinski: You can note that, you know, that Laura Zwolinski: No longer, no longer, reported. And, in addition, Laura Zwolinski: You know, if it's still a quality metric that you're interested in, you can, you know, retain that and update just the, sort of the way that you, Laura Zwolinski: The benchmark that… or the goal that you're setting, moving forward, if it… if it's of interest to… to the plan to continue on with, depending on… on what it is. METELMI: Okay, but, like, once it's in, we don't need to, like, remove it if, like, the following year or something like that, it, like, goes away, we could just put in, you know, that this was retired and we don't have the necessary information, or we're tracking it ourselves, so… Laura Zwolinski: Yes. Yes. Laura Zwolinski: Yeah. Daniel Lehman: Yeah, and I would just add that, Daniel Lehman: You know, in the regulations, there are certain… Daniel Lehman: when there are certain things that change in the mock, the plan must submit an off-cycle submission. This is not one of them, and so you wouldn't have to… you're not necessarily be held responsible for Daniel Lehman: not submitting an off-cycle in these instances. I think you can, again, like we've been saying, you can update it on the renewal document, just saying what had happened. METELMI: Okay, perfect. Thank you. Laura Zwolinski: Thank you so much for your question. Laura Zwolinski: And that would work, work out a little bit differently for CSTIMPs, just because they do have the annual submission cycle available to them, and they would be able to update that information on an annual basis. Laura Zwolinski: We'll give it a few more minutes just to see if we receive any additional questions in the chat, or if anyone would like to raise their hand and ask a question, and Laura Zwolinski: If otherwise, we will go ahead and conclude the call. Laura Zwolinski: Okay, it looks like we do have an additional question that came into the Q&A, and the question is, do we need to include links to our community resources listing? Laura Zwolinski: Thank you for that question, and the answer is no. There is no, requirement to include, direct links to your community resources. That said. Laura Zwolinski: Some plans do include that information, and some plans don't, so, it's… Laura Zwolinski: Up to the discretion of the plan as to whether or not you'd like to include that. Laura Zwolinski: However, it is… it is not a requirement. Shree Patel: Thank you for that, Lauren. Shree Patel: And we have one more question here. If our plan has less than 10 members, would you expect us to use proxy data for our population assessment? Laura Zwolinski: Thank you for the question. Laura Zwolinski: In this instance, I think we'd leave it up to the discretion of the plan. We don't… CMS and NCQA are not prescriptive as to whether or not you're using your own data, or Laura Zwolinski: Proxy data, when they are… when you get to a place where you feel like there are limitations to the data that you're able to use, particularly if the entirety of the plan has 10 members. Laura Zwolinski: Understanding that the vulnerable population would have even less. This is an instance in which Laura Zwolinski: Plans may use proxy data, but again, if that is the case, please be very specific about the rationale for the use of the proxy data, especially if you are a renewal plan that has been in operations for 2 years or more. Shree Patel: Thank you again, Laura. Shree Patel: And we will ask if anyone has any more questions, please put them in the Q&A. Shree Patel: Or please raise your hand, and if not, we can go ahead and begin closing remarks. Shree Patel: Looks like we have one more question here. Shree Patel: The question is, for ISNPs, when members have cognitive impairment, how should consent for face-to-face encounters be obtained if there are no responsible parties involved? Daniel Lehman: So I think it's one of those questions where you, you know, if it's, Daniel Lehman: Might be working with a facility if, if they're in a long-term care institution. Daniel Lehman: Around that. But we understand there may be challenges. Daniel Lehman: We also recognize this for face-to-face encounters, you could also use any sort of Daniel Lehman: existing, evidence of utilization. Daniel Lehman: for the required, you know, HRA. Daniel Lehman: So… I think there are some options there, if there are difficulties in obtaining, Daniel Lehman: Consent. Shree Patel: Thank you, Dan. Shree Patel: Again, we'll do one final call for questions. Shree Patel: Before we conclude. Laura Zwolinski: Okay. Laura Zwolinski: All right, there's one, one final question came through in the chat, and that's, where can we access the meeting recording and transcript? Thank you for the question. The meeting recording and transcript will be posted to, the SNP approval website under the resources section. Laura Zwolinski: And with that, Laura Zwolinski: We wanted to take the time to thank you for your time and attention today, all of your engagement and your great questions during today's SNP Model of Care pre-submission Technical Assistance call. Have a wonderful afternoon, and please take care, everyone. This concludes our call this afternoon.