Why element-level scoring is the new hurdle for SNPs
As we navigate the long and winding road of 2026, a new deadline is fast approaching: the May 2026 submission window for CY 2027 guidelines. The Model of Care (MOC) has evolved into a high-stakes precision test where element-level scoring is unforgiving.
The Reality of the 2027 Guidelines
Missed factors can now trigger a “cure” submission, which for D-SNPs and I-SNPs can lead to a reduced approval duration.
High-Impact Changes:
The 100% Standard: Completion goals for HRA, ICP, and ICT are now expected to be set at 100%.
Data Recency: Plans at least two years old can no longer use census or proxy data; actual contract-specific SNP data from 2022 or later is required.
Vulnerability Depth: MOC 1A expanded—plans must now describe both the general population and the most vulnerable subpopulation, including health disparities and demographics.
Structural Updates: The total number of elements has been reduced from 16 to 15, requiring a renumbered crosswalk of your prior content.
Practical Pitfalls to Avoid
Where do plans most often lose points?:
Generic Descriptions: Failing to differentiate the “most vulnerable” from the general population with clear stratification logic.
Goal Lapses: Listing measurable goals without including prior-year results or a credible remediation plan for when goals are not met.
Vague Workflows: Describing ICT communications or ICP updates at a high level without identifying the “who, when, and how”.
30-60 Day Readiness Steps:
Build a 2027 “Data Pack”: Gather contract-specific data (2022+) for both general and most vulnerable populations.
Complete a Gap Analysis: Run a factor-level crosswalk that includes complex D-SNP Medicaid coordination touchpoints.
Validate Operational Workflows: Confirm Care Mgmt, UM, and Quality owners can execute on new HRA stratification and ICT mandates.
Technical Narrative Overhaul: Rewrite the MOC in guideline order using audit-ready language and clear evidence cues (Who/When/How).
- CY-2027-SNP-MOC-Readiness-Guide-ATTACConduct a line-by-line QA to ensure every element-level scoring threshold is met before submission.
How ATTAC Can Help
From a Rapid 1–2 Week Crosswalk to a Full 3–6 Week Narrative Rewrite, we ensure your MOC is aligned with the latest CMS expectations.
Contact our compliance experts for a MOC Readiness Review.
Don’t Navigate the Long and Winding Road Alone
The regulatory landscape is shifting from periodic checks to constant enforcement. Managing this complexity requires more than just reactive fixes: it requires a strategic, flexible extension of your team.
Introducing ATTAC Assurance: Your Flexible Compliance Partner
We’ve designed ATTAC Assurance to turn regulatory chaos into operational clarity. Led by industry veterans like Regan Pennypacker and Anne Crawford—leaders who have sat in the chair and managed these same pressures—our program provides the exact support you need, exactly when you need it.
How Assurance Members Stay Ahead:
On-Demand Expertise: Access a flexible bank of consulting hours (60 or 120) to address specific hurdles like remediation, operational support, or targeted reviews.
Exclusive Project Execution: Members receive exclusive pricing on deep-dive services, including Audit Readiness (ODAG/CDAG) and Risk Adjustment Program Assessments.
Regulatory Intelligence: Stay focused on impact with weekly ATTAC Alerts on critical CMS HPMS memos and quarterly industry trend digests.
Custom Training: Annual training days tailored specifically to your team’s operational reality.
Stop reacting to the noise. Start building a defensible, proactive compliance strategy with the experts who know the road ahead.
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