By Lisa Hardisty, Senior Director, Compliance Solutions, ATTAC Consulting Group
At a recent SNP conference, I asked a few plan representatives a direct question:
“Have you taken your Model of Care, broken it down element by element, and checked that everything you committed to is actually reflected in your policies, training, operations, and monitoring?”
More than once, the answer was some version of, “Oh my gosh, we never even thought to do that.”
That gap has been on my mind again now that the May submission deadline has passed. If your plan submitted a CY2027 Model of Care, congratulations on clearing a substantial hurdle that likely required quite a bit of intense rewriting. But submission isn’t the finish line – it’s the starting line of a six-month window before your commitments go live on January 1, and this year that window comes with higher expectations to demonstrate you are carrying out the commitments you’ve made.
What CMS Changed for CY2027 Model of Care Requirements
A quick recap, because these changes are still shaping what auditors will be looking for in a few months:
- MOC 1A now requires a separate description of the general SNP population and the most vulnerable subpopulation, with demographics, health status, and the factors driving health disparities for each.
- MOC 1B asks for a defined methodology for identifying your most vulnerable members, care management practices tied to that methodology, and a service-area partnership list with an honest accounting of where those partnerships fall short.
- MOC 4B raised completion goals for HRAs, ICPs, and ICTs to 100%, and now requires a look-back on prior-year goals — met or not — with a remediation plan wherever they weren’t.
- The structure changed too: 16 elements became 15. The old 4D folded into 4A, and 4E was renumbered to 4D.
- Data has to be current and contract-specific, nothing older than 3 years. Plans more than two years old can no longer rely on census or national proxy data; it has to be actual SNP membership data.
- Scoring moved to the element level: a minimum 50% threshold on each of the 15 elements, on top of the 70% overall requirement. That means one weak element can trigger a cure even when the overall score passes. For D-SNPs and I-SNPs, a required cure caps the approval at one year regardless of the post-cure score.
CMS isn’t asking plans to state intent anymore. It wants to see, factor by factor, how each commitment gets executed. That’s a meaningfully higher bar, and clearing it on paper is only half the job.
Two Things Are True for Your Plan Right Now
The commitments you wrote into your CY2027 MOC are operational promises now, ones CMS expects to see executed starting January 1, with audit notices typically beginning in February. Regulatory teams are usually well practiced at tracking CMS requirements. The Model of Care, though, gets written by clinical and operational teams, and it can drift out of the regulatory team’s line of sight after submission. That disconnect is exactly where citations happen, even for plans that are otherwise compliant. It’s how two of our current clients found us, both after gaps surfaced between what they’d written and what their operations could actually demonstrate.
At the same time, the standard CMS just raised for CY2027 is unlikely to loosen for CY2028. Element-level scoring, 100% completion expectations, and contract-specific data requirements read like the new baseline, not a one-year exception. Plans that wait until next spring to start their CY2028 redlines will be trying to do, in a few weeks, what this cycle showed takes real lead time to do well. Starting now, while the CY2027 factors and your own submission are still fresh is the difference between a comfortable runway and a scramble.
How ATTAC Helps SNP Plans Execute on MOC Commitments
We work with plans to:
- Write realistic Models of Care that meet CMS requirements while also being operationally practical;
- Determine if plans are doing what they say they are doing;
- Remediate gaps by implementing changes to bring operations into compliance with the MOC; and,
- Ensure audit readiness before the next audit cycle begins.
For the commitments you just submitted, we build a Model of Care Traceability Matrix that maps every element of your MOC to the policies, desktop procedures, training, systems, and monitoring required to support it. The result is a risk-ranked gap assessment, so you know exactly where operations don’t yet match the MOC, before an auditor finds it for you. Where gaps exist, we help close them, from policy rewrites to reporting design to workflow and system changes.
For the redlines ahead, within 6 weeks of project initiation we run a CY2027 crosswalk and gap score against your current MOC, build a full rewrite package in guideline order with audit-ready evidence cues, refresh your MOC 4A/4B goals framework to meet the 100% completion mandate with a credible look-back built in, perform line-by-line factor verification, and deliver a submission-ready deliverable set.
Whether you’re just starting to contemplate your MOC rewrite or you’re at the starting line for 2027 implementation, the goal is the same: make commitments you can actually carry out and ensure what’s written matches what actually happens. If you’d like to make sure your MOC is both achievable on paper and in practice, please reach out to us at inquiry@attacconsulting.com.
Lisa Hardisty is Senior Director, Compliance Solutions at ATTAC Consulting Group, where she leads SNP Model of Care and compliance program work for health plan clients. She brings more than 25 years of healthcare experience across utilization management, case management, compliance, delegation oversight, data analytics, and long-term care, including 18 years inside managed care organizations spanning Medicare, Medicaid, Commercial, ASO, FEHBP, and AHA lines of business. She holds a Bachelor of Arts in Political Science from the University of New Mexico and is Certified in Healthcare Compliance (CHC).
