This presentation is to provide an overview of the Special Needs Plans or SNP Application
process.
the topics we will cover are:
A brief SNP overview of what a SNP is The SNP application timeline
SNP Application Requirements SNP Application Elements in the Health Plan
Management System (HPMS) Important Updates & Reminders and
SNP Resources SNPs were created by Congress in the Medicare
Modernization Act (MMA) of 2003, as a new type of Medicare managed care plan that focused
on certain vulnerable groups of Medicare beneficiaries.
The Bipartisan Budget Act of 2018 permanently authorized SNPs which includes: dual-eligible
SNPs (D-SNPS), chronic condition SNPs (C-SNPs) and institutional SNPs (I-SNPs).
SNPs are a type of Medicare Advantage (MA) plan and must follow existing MA program rules.
The timeline for submitting a SNP application is the same as the MA application.
All SNP applications are due in Feb.
An HPMS memo is sent out in January to notify plans of the application deadline.
Applicants will be notified of initial review results in March, the 2nd round of review
results will go out in April, and conditional approval and denial notices will go out in
late May.
D-SNPs that are conditionally approved are required to submit State Medicaid Agency Contracts
in July.
That process will be discussed later in this presentation.
Now let’s go over the SNP application requirements.
All SNPs must provide Part D prescription drug coverage.
Organizations that want to offer a SNP, must be approved at the MA level and may only operate
a SNP in it’s MA-PD approved service area.
If an applicant seeks to offer different SNP types, an application must be completed for
each SNP type the organization plans to offer.
For example: If an organization is planning to offer a D-SNP and a I-SNP, you must complete
both a D-SNP and I-SNP application.
SNP applications must be triggered in HPMS.
If you submit an MA application that is strictly for MA.
If you want to offer a SNP you have to complete and submit a separate SNP application.
Each year we have situations where organizations forget to trigger the SNP application or thought
they submitted a SNP application but only submitted an application for MA.
Please make sure you receive a confirmation for your SNP application submission.
CMS adheres to a strict deadline and does not grant extensions.
The good thing is that there are now pop ups in HPMS that will ask if you would like to
trigger a SNP application.
You can refer to the HPMS application training for more information regarding triggering
the SNP application in HPMS.
The information is also in the SNP User Guide in HPMS.
If you are a new applicant or an existing MA organization seeking to offer a SNP for
the first time you will need to complete an initial SNP application.
Please keep in mind if your MA application is not approved then your SNP application
will not be approved.
The Model Of Care (MOC) Matrix Upload Documents and the MOC Narrative are required to be uploaded
with all initial SNP applications.
Existing MA organizations that want to expand the service area of a current SNP must complete
an SAE application.
The service area of the SNP cannot exceed the existing or pending MA service area.
For example: If an applicant is planning to add a county to a current D-SNP under an existing
contract number and the county has not been approved at the MA level – you must complete
an SAE at both the MA and SNP level.
The MOC Matrix Upload Documents and the MOC Narrative are not required for SNP SAE applications.
Existing SNPs that are not expanding their service areas but are required to renew under
the National Committee for Quality Assurance SNP Approval Process are only required to
submit a MOC written Narrative and a MOC Matrix Upload Document in the MOC Module.
Please note: C-SNPs must submit a MOC annually.
For more details regarding MOC submissions, please refer to the “Changes to the Model
of Care Submission Requirements,” issued November 28, 2018.
There is also a “Model of Care Training” HPMS memo released in January.
This memo also provides information for MOC trainings that are offered to assist with
MOC submissions.
Completing a SNP application in HPMS consist of attestations and uploads.
Attestations substitute for providing the actual documented evidence of the organizations’
anticipated ability to meet specific SNP requirements at the time of submitting the application
and uploads are supporting documentation that the applicant is required to submit into HPMS.
There are SNP-specific upload documents which are described throughout the SNP attestation
sections.
Please read the sections carefully in order to provide the information as requested.
Please note: MA forms are not required along with the SNP application.
These approvals are done at the MA level and must be met in order to offer a SNP.
We will now go over the specific application requirements for each SNP type starting with
C-SNPs.
C-SNPs restrict enrollment to special needs individuals with specific severe or disabling
chronic conditions.
When completing the SNP application, organizations may apply to offer a C-SNP that targets any
one of the following: *A single CMS-approved chronic condition - please
refer to chapter 16b for the list of the approved 15 SNP-specific chronic conditions
*A CMS-approved group of commonly co-morbid and clinically-linked conditions or
*An MAO-customized group of multiple chronic conditions – which are described in Chapter
16b There are no C-SNP specific uploads, however
MOC upload documents are required for both Initial and Renewal C-SNP applications.
We receive a lot of questions about combining C-SNPs.
Please note: If you offer a C-SNP and are seeking to change or offer a new C-SNP type,
a new application is required.
For example: If you are currently approved for a Chronic Heart Failure C-SNP and you
want to offer a Chronic Lung Disorder C-SNP, then you will have to complete a new application
with a new MOC specific to that chronic condition.
Organizations can apply to offer three types of I-SNPs: an Institutional Only SNP, an Institutional
Equivalent Only SNP for individuals living in the community , and a combined Institutional
and Institutional Equivalent SNP.
Institutional only SNPs restrict enrollment to MA eligible individuals who require a level
of care service in a long-term care facility.
A complete list of acceptable types of institutions can be found in the Medicare Advantage Enrollment
and Disenrollment Guidance at cms.gov.
An Institutional Equivalent SNP enrolls MA eligible individuals living in the community,
but require an institutional level of care.
For the institutional only SNP there is only one upload document which is the I-SNP Individuals
Residing ONLY in Institutions upload document.
This document requires a signature by an authorized representative at the applicants organization.
Please note : a contractor would not meet this requirement.
The document also request a list of contracted long term care facilities.
Please only list the facilities you are contracted with at the time of the application submission.
The institutional equivalent SNP upload requirements includes the I-SNP residing Only in Community
upload document which also requires a signature by an authorized representative and a Copy
of the respective State’s Level of Care (LOC) assessment tool to determine eligibility
for each institutional equivalent beneficiary.
Please ensure it is clear which state the LOC assessment is for.
There should be some indication that the document submitted is a comprehensive tool used to
assess the target population.
The combined Intuitional and Community I-SNP requires the I-SNP Individuals Residing in
Both Institutions and the Community upload document again that requires a signature by
an authorized representative and a copy of the respective State’s Level of Care (LOC)
assessment tool.
MOC upload documents are also required for both Initial and Renewal I-SNP applications.
We also receive a lot of questions with organizations wanting to combine I-SNPs.
Please note: If you offer an I-SNP and are seeking to change or offer a new I-SNP type
a new application is required.
For example: If you are currently approved for an Institutional Only I-SNP and you want
to offer a Institutional Equivalent I-SNP then a new application would be required.
Or if you currently offer an Institutional Equivalent I-SNP and you want to offer a combined
Institutional and Institutional Equivalent I-SNP, then you will have to complete a new
application.
Last but not least D-SNPs.
D-SNPs enroll individuals who are entitled to both Medicare and medical assistance from
a state plan under Medicaid.
With the D-SNP Application you are required to submit a State Medicaid Agency Contract
and Matrix which is used to identify key elements in the state contract , the Special Needs
Plan Contract Status Review Matrix which is used to determine the D-SNP integration status
and the MOC upload documents.
SMAC submissions are not submitted with SNP applications.
Information regarding the submission of SMACs is released in May and all SMACs are due in
HPMS in July in the D-SNP Management module each year.
All SMACs should be signed and executed by the July due date.
D-SNP integration statues will also be determined during the SMAC reviews.
Here are a few important updates and reminders: Beginning in CY2021, the 21st Century Cures
Act allowed Medicare-eligible individuals with ESRD to enroll in Medicare Part C MA
managed care plans.
As a result, applicants are no longer required to request an ESRD waiver when completing
the SNP application.
All SNP Applications are due in February.
Please make sure you trigger the SNP application if you are applying for a SNP and please make
sure you hit final submit and receive a confirmation for each application you submit.
I cannot not stress this enough.
CMS does not grant extensions.
These are resources that are available regarding the SNP application.
Please submit any SNP application questions to the DMAO portal and select the SNP category
so that it can go directly to the SNP team.
Thank you for your time.