US · guidance
CMS Pub. 100-16, ch. 5, § 20.2.2
Model of Care Scoring Criteria
The NCQA scoring approval process is based on scoring each of the clinical and non-clinical
elements of the MOC as part of the SNP application. The scoring guidelines were revised to
align with the new MOC structure to be utilized starting with the CY 2015 application cycle and
are modeled after the Structure & Process Measures format. The revised scoring guidelines
complement the new MOC structure and help SNPs better understand and meet the requirements
of the revised MOC element structure.
MOC 1: Description of SNP Population (General Population)
Identification and a comprehensive description of the SNP-specific population are integral
components of the MOC. All elements in this standard depend on a complete population
description that addresses the full continuum of care of current and potential SNP beneficiaries,
including end-of-life needs and considerations (if relevant).
SNPs must include a complete description of specially tailored services for beneficiaries
considered especially vulnerable (refer to Element 1B), using specific terms and details (e.g.,
members with multiple hospital admissions within three months, “medication spending above
$4,000”).
Element A: Description of Overall SNP Population
The organization’s MOC description of its target SNP population must:
1. Describe how the health plan staff will determine, verify and track eligibility of SNP
beneficiaries.
2. Describe the social, cognitive and environmental factors, living conditions and
co-morbidities associated with the SNP population.
3. Identify and describe the medical and health conditions impacting SNP beneficiaries.
4. Define the unique characteristics of the SNP population served.
Scoring 100% 80% 50% 20% 0%
The
organization
meets all 4
factors
The
organization
meets 3
factors
The
organization
meets 2
factors
The
organization
meets 1
factor
The
organization
meets no
factors
Explanation Element Target population characteristics
The organization’s description of its target population is an integral component
of the MOC narrative that provides a fundamental foundation on which the
other elements build to develop a comprehensive program that fully addresses
the continuum of care for its beneficiaries.
The organization’s MOC must show how it identifies its members and must
describe the target population that includes specific information on the
characteristics of the population it intends to serve. This information must
include specific components that characterize its beneficiaries, such as average
age, gender and ethnicity profiles, the incidence and prevalence of major
diseases, chronic conditions and other significant barriers faced by the target
population.
The organization may use beneficiary information from other product lines
(e.g., Medicare Advantage or Medicaid plans) as an example of the intended
target population if the plan does not have members, or it must provide details
compiled from the intended plan service area.
Factor 1: Determine, verify and track eligibility
The organization must have a process for identifying, verifying and tracking
SNP beneficiaries to ensure eligibility for appropriate care coordination
services. The MOC description must include information on the relevant
resources (systems or data collection methodology) used to perform these
tasks.
Factors 2, 3: Identify health conditions
The MOC description includes specific information on the current health status
of its SNP beneficiaries and characteristics that may impact their status. Factor
2 should include descriptions of the demographic, social and environmental
factors, and living conditions associated with the SNP population such as
average age, gender, ethnicity and potential health disparities associated with
certain groups, such as language barriers, deficits in health literacy, poor
socioeconomic status, cultural beliefs or barriers that may interfere with
conventional provision of health care or services, caregiver considerations or
other concerns. Factor 3 should identify and describe the medical and cognitive
factors, co-morbidities and other health conditions that affect SNP
beneficiaries.
Factor 4: Define unique characteristics of the SNP population (plan type)
Each SNP type (Chronic [C-SNP], Dual-Eligible [D-SNP] or Institutional [I-SNP]) description must include the unique health needs of beneficiaries
enrolled in each plan as well as limitations and barriers that may pose
challenges affecting their overall health:
• C-SNPs:
– Describe chronic conditions, incidence and prevalence as related to the
target population covered by this SNP.
• The description must include information on limitations and barriers
that pose potential challenges for beneficiaries (e.g., multiple co-morbidities, lack of care coordination between multiple providers)
• D-SNPs:
– Describe dual-eligible members, such as full duals or partial duals.
• The description must include information on limitations and barriers
that pose potential challenges for beneficiaries (e.g., gaps in
coordination of benefits between Medicare and Medicaid, poor health
literacy).
• I-SNPs:
– Specify the facility type and provide information about facilities where
SNP beneficiaries reside (e.g., long term care facility, home or
community-based services).
– Include information about the types of services, as well as about the
providers of specialized services.
• The description must include information on limitations and barriers
that pose potential challenges for beneficiaries (e.g., dementia, frailty,
lack of family/caregiver resources or support).
Element B: Subpopulation—Most Vulnerable Beneficiaries
The organization must have a complete description of the specially tailored services it
provides to its most vulnerable members that:
1. Defines and identifies the most vulnerable beneficiaries within the SNP population and
provides a complete description of specially tailored services for such beneficiaries.
2. Explains how the average age, gender, ethnicity, language barriers, deficits in health
literacy, poor socioeconomic status, as well as other factors, affect the health outcomes
of the most vulnerable beneficiaries.
3. Illustrates a correlation between the demographic characteristics of the most vulnerable
beneficiaries and their unique clinical requirements.
4. Identifies and describes established relationships with partners in the community to
provide needed resources.
Scoring 100% 80% 50% 20% 0%
The
organization
meets all 4
factors
The
organization
meets 3
factors
The
organization
meets 2
factors
The
organization
meets 1
factor
The
organization
meets no
factors
Explanation Factor 1: Define most vulnerable beneficiaries
Although the definition of “SNP beneficiary” typically implies members
requiring additional care and services, the description focuses on the sickest or
most vulnerable SNP members.
The organization’s MOC must include a robust and comprehensive definition
that describes who these members are (i.e., what sets them apart from the
overall SNP population), the methodology used to identify them (e.g., data
collected on multiple hospital admissions within a specified time frame; high
pharmacy utilization; high risk and resultant costs; specific diagnoses and
subsequent treatment; medical, psychosocial, cognitive or functional
challenges) and specially tailored services for which these beneficiaries are
eligible.
The organization may use beneficiary information from other product lines
(e.g., Medicare Advantage or Medicaid plans) as an example of the intended
target population if the plan does not have members, or it must provide details
compiled from the intended plan service area.
Factors 2 & 3: Correlation between demographic characteristics and
clinical requirements
The organization’s MOC definition of its most vulnerable beneficiaries must
describe the demographic characteristics of this population (i.e., average age,
gender, ethnicity, language barriers, deficits in health literacy, poor
socioeconomic status and other factors) and specify how these characteristics
combine to adversely affect health status and outcomes and affect the need for
unique clinical interventions.
The definition must include a description of special services and resources the
organization anticipates for provision of care to this vulnerable population.
Factor 4: Establish relationships with community partners
The organization’s MOC must describe its process for partnering with
providers within the community to deliver needed services to its most
vulnerable members, including the type of specialized resources and services
provided and how the organization works with its partners to facilitate member
or caregiver access and maintain continuity of services.
MOC 2: Care Coordination
Care coordination helps ensure that SNP beneficiaries’ health care needs, preferences for health
services and information sharing across health care staff and facilities are met over time. Care
coordination maximizes the use of effective, efficient, safe, high-quality patient services
(including services furnished outside the SNP’s provider network) that ultimately lead to
improved health care outcomes.
The following MOC sub-elements are essential components to consider in the development of a
comprehensive care coordination program; no sub-element must be interpreted as being of
greater importance than any other. Taken together, all five sub-elements must address the SNP’s
care coordination activities comprehensively.
Element A: SNP Staff Structure
The organization’s MOC must:
1. Describe the administrative staff’s roles and responsibilities, including oversight
functions.
2. Describe the clinical staff’s roles and responsibilities, including oversight functions.
3. Describe how staff responsibilities coordinate with the job title.
4. Describe contingency plans used to address ongoing continuity of critical staff functions.
5. Describe how the organization conducts initial and annual MOC training for its
employed and contracted staff.
6. Describe how the organization documents and maintains training records as evidence
that employees and contracted staff completed MOC training.
7. Describe actions the organization takes if staff do not complete the required MOC
training.
Scoring 100% 80% 50% 20% 0%
The
organization
meets 6-7
factors
The
organization
meets 4-5
factors
The
organization
meets 3
factors
The
organization
meets 1-2
factors
The
organization
meets no
factors
Explanation Factor 1: Administrative staff roles and responsibilities
The organization’s MOC defines staff roles and responsibilities across all
health plan functions for personnel that directly or indirectly affect the care
coordination of SNP beneficiaries.
The organization’s MOC must identify and describe the specific employed and
contracted staff responsible for performing administrative functions, including:
• Enrollment and eligibility verification.
• Claims processing.
• Administrative oversight.
Factor 2: Clinical staff roles and responsibilities
The organization must identify and describe the employed and contracted staff
that perform clinical functions, including:
• Direct beneficiary care and education on self-management techniques.
• Care coordination.
• Pharmacy consultation.
• Behavioral health counseling.
• Clinical oversight.
Staff oversight responsibilities must include any license and competency
verification that relates to the specific population being served by the
organization (e.g., geriatric training for I-SNP providers or special training for
physicians and other clinical staff for a C-SNP services beneficiaries with
HIV/AIDs; data analyses for utilization of appropriate and timely health care
services; utilization review; and provider oversight to ensure use of appropriate
clinical practice guidelines and integration of care transition protocols.
Factor 3: Coordination of responsibilities and job title
To show how staff responsibilities identified in the MOC are coordinated with
job title, the organization must provide a copy of its organization chart and, if
applicable, a description of instances when a change to staff title/position or
level of accountability is required to accommodate operational changes in the
SNP.
Factor 4: Contingency plan
The organization must have a contingency plan (or plans) in place to avoid a
disruption in care and services when existing staff can no longer perform their
roles and meet their responsibilities. The organization’s MOC must identify
and describe contingency plans to ensure ongoing continuity of staff functions.
Factors 5, 6: Initial and annual MOC training; maintaining training
records
The organization must conduct initial and annual MOC training for its
employed and contracted staff. The MOC must describe the training strategies
and content, as well as the methodology the organization uses to document and
maintain training records as evidence that staff have completed MOC training.
Contracted staff does not include physicians or other providers that the
organization contracts with as part of the provider network.
The description must include types of trainings and specific examples of slides
or training materials. If the training plan is not currently operational, the
organization’s MOC must provide a description of the plan’s contents.
Factor 7: Actions if training is not completed
The organization’s MOC must explain challenges associated with employed
and contracted staff completing training and must describe actions the
organization will take when the required MOC training has not been completed
or has been found to be deficient.
Element B: Health Risk Assessment Tool (HRAT)
The organization’s MOC includes a clear and detailed description of the policies and
procedures for completing the HRAT that addresses:
1. How the organization uses the HRAT to develop and update the Individualized Care
Plan (ICP) for each beneficiary (Element 2C).
2. How the organization disseminates the HRAT information to the Interdisciplinary Care
Team (ICT) and how the ICT uses that information (Element 2D).
3. How the organization conducts the initial HRAT and annual reassessment for each
beneficiary.
4. The detailed plan and rationale for reviewing, analyzing and stratifying (if applicable),
the HRA results.
Scoring 100% 80% 50% 20% 0%
The
organization
meets all 4
factors
The
organization
meets 3
factors
The
organization
meets 2
factors
The
organization
meets 1
factor
The
organization
meets no
factors
Explanation The content of and methods used to conduct the HRAT have a direct effect on
the development of the ICP and ongoing coordination of ICT activities. The
HRAT must assess the medical, functional, cognitive, psychosocial and mental
health needs of each SNP beneficiary.
Factors 1&2: Use and dissemination of HRAT information
The organization must include a description of how the HRAT is used to
develop and update, in a timely manner, the ICP for each beneficiary and how
the HRAT information is disseminated to and used by the ICT.
Factor 3: Initial HRA and annual reassessment
The organization must complete the HRAT for each beneficiary, for initial
assessment, and must complete an HRAT annually thereafter. At minimum, the
organization must conduct initial assessment within 90 days of enrollment and
must conduct annual reassessment within one year of the initial assessment.
The description must include the methodology used to coordinate the initial and
annual HRAT for each beneficiary (e.g., mailed questionnaire, in-person
assessment, phone interview) and the timing of the assessments. There must be
a provision to reassess beneficiaries, if warranted by a health status change or
care transition (e.g., hospitalization, change in medication, multiple falls). The
organization must describe its process for attempting to contact beneficiaries
and have them complete the HRAT, including provisions for beneficiaries that
cannot or do not want to be contacted or complete the HRAT.
Factor 4: Plan and rationale
The organization’s MOC must describe its plan and explain its rationale for
reviewing, analyzing and stratifying HRAT results. It must include the
mechanisms for communicating information to the ICT, provider network,
beneficiaries and/or their caregiver(s) and other SNP personnel who may be
involved with overseeing a beneficiary’s plan of care. If the organization uses
stratified results, the MOC must explain how the SNP uses the results to
improve the care coordination process.
Element C: Individualized Care Plan (ICP)
The description of the organization’s ICP must include:
1. The essential components of the ICP.
2. The process to develop the ICP, including how often the ICP is modified as
beneficiaries’ health care needs change.
3. The personnel responsible for development of the ICP, including how the beneficiary
and/or caregiver(s) are involved.
4. How the ICP is documented, updated and where it is maintained.
5. How updates and modifications to the ICP are communicated to the beneficiary and
other stakeholders.
Scoring 100% 80% 50% 20% 0%
The
organization
meets all 5
factors
The
organization
meets 4
factors
The
organization
meets 2-3
factors
The
organization
meets 1
factors
The
organization
meets no
factors
Explanation Factor 1: ICP essential components
The organization must develop an ICP for each beneficiary, to deliver
appropriate care to the beneficiary. The organization’s ICP must include, but is
not limited to:
• The beneficiary’s self-management goals and objectives.
• The beneficiary’s personal healthcare preferences.
• A description of services specifically tailored to the beneficiary’s needs.
• Identification of goals (met or not met).
– If the beneficiary’s goals are not met, the organization’s MOC must
describe the process for reassessing the current ICP and determining
the appropriate alternative actions.
Factors 2, 3: ICP development process and personnel
The organization’s MOC must describe the process for developing the ICP and
must detail the personnel responsible for developing the ICP. The description
of responsible staff must include roles and functions, professional requirements
and credentials necessary to perform these tasks, as well as how the beneficiary
or their caregiver/ representative is involved in the ICP development. The MOC
must also include a description of how the organization determines how often
to review and modify, as appropriate, the ICP as the beneficiary’s health care
needs change.
Factor 4: ICP documentation and maintenance
The organization’s MOC must describe how the ICP is documented and
updated and where the documentation is maintained so it is accessible to the
ICT, provider network and beneficiaries and/or their caregiver(s).
Factor 5: Updates and modifications
The organization’s MOC must describe how the organization communicates
ICP updates and modifications to beneficiaries and/or their caregiver(s), the
ICT, applicable network providers, other SNP personnel and other
stakeholders, as necessary.
Element D: Interdisciplinary Care Team (ICT)
The organization’s MOC must describe the critical components of the ICT, including:
1. How the organization determines the composition of ICT membership.
2. How the roles and responsibilities of the ICT members (including beneficiaries and/or
caregiver[s]) contribute to the development and implementation of an effective
interdisciplinary care process.
3. How ICT members contribute to improving the health status of SNP beneficiaries.
4. How the SNP’s communication plan to exchange beneficiary information occurs
regularly within the ICT, including evidence of ongoing information exchange.
Scoring 100% 80% 50% 20% 0%
The
organization
meets all 4
factors
The
organization
meets 3
factors
The
organization
meets 2
factors
The
organization
meets 1
factor
The
organization
meets no
factors
Explanation Factor 1: ICT membership
The organization’s MOC must describe the composition of the ICT, including
how the SNP determines ICT membership and the roles and responsibilities of
each member. The description must specify how the expertise and capabilities
of the ICT members align with the identified clinical and social needs of the
SNP beneficiaries.
The organization must:
• Explain how the SNP facilitates the participation of beneficiaries and their
caregiver(s) as members of the ICT.
• Describe how the beneficiary’s HRAT and ICP are used to determine the
composition of the ICT; including where additional team members are
needed to meet the unique needs of a beneficiary.
• Explain how the ICT uses health care outcomes to evaluate processes
established to manage changes or adjustments to the beneficiary’s health
care needs on a continuous basis.
Factors 2 and 3: ICT member roles and responsibilities
The organization’s MOC must describe how it uses clinical managers, case
managers and others who play critical roles in providing an effective
interdisciplinary care process; and how beneficiaries and/or their caregiver(s)
are included in the process, are provided with needed resources and how the
organization facilitates access for beneficiaries to ICT team members.
Factor 4: Communication plan
The MOC must describe the SNP’s communication plan for promoting regular
exchange of beneficiary information within the ICT. The MOC must show:
• Clear evidence of an established communication plan that is overseen by
SNP personnel who are knowledgeable and connected to multiple facets
of the SNP MOC.
• How the SNP maintains effective and ongoing communication among
SNP personnel, the ICT, beneficiaries and/or their caregiver(s),
community organizations and other stakeholders.
• The types of evidence used to verify that communications have taken
place (e.g., written ICT meeting minutes, documentation in the ICP).
• How communication is conducted with beneficiaries who have hearing
impairments, language barriers and cognitive deficiencies.
Element E: Care Transition Protocols
The organization’s MOC describes the following care transition protocols:
1. How the organization uses care transition protocols to maintain continuity of care for
SNP beneficiaries.
2. The personnel responsible for coordinating the care transition process.
3. How the organization transfers elements of the beneficiary’s ICP between health care
settings when the beneficiary experiences an applicable transition in care.
4. How beneficiaries have access to personal health information to facilitate
communication with providers in other healthcare settings.
5. How beneficiary and/or caregiver(s) will be educated about the beneficiary’s health
status to foster appropriate self-management activities.
6. How the beneficiary and/or caregiver(s) are informed about the point of contact
throughout the transition process.
Scoring 100% 80% 50% 20% 0%
The
organization
meets all 6
factors
The
organization
meets 4-5
factors
The
organization
meets 3
factors
The
organization
meets 1-2
factors
The
organization
meets no
factors
Explanation Definitions
• Health care setting: The provider from whom or setting where a member
receives health care and health-related services. In any setting, a designated
practitioner has ongoing responsibility for a member’s medical care.
– Settings include home, home health care, acute care, skilled nursing
facility, custodial nursing facility, rehabilitation facility and
outpatient/ambulatory care/surgery centers.
• Transition: Movement of a member from one care setting to another as the
member’s health status changes.
– For example, moving from home to a hospital as the result of an
exacerbation of a chronic condition or moving from the hospital to a
rehabilitation facility after surgery.
• Transition process: The period from identification of a member who is at
risk for a care transition through completion of a transition.
– This process includes planning and preparation for transitions and the
follow-up care after transitions are completed.
Factor 1: Continuity of care
Older or disabled adults moving between different health care settings are
particularly vulnerable to receiving fragmented and unsafe care when
transitions are poorly coordinated; thus, an organization must work actively to
coordinate transitions. The organization must specify the process and rationale
for connecting beneficiaries with the appropriate providers.
Factor 2: Care transition personnel
The organization must identify and describe the personnel (e.g., case manager)
responsible for coordinating the care transition process and for ensuring that
follow-up services and appointments are scheduled and performed.
Factor 3: Applicable transitions
The organization must ensure that elements of the beneficiary’s ICP are
transferred between health care settings when the beneficiary experiences a
transition in care. The MOC must describe the steps that take place before,
during and after a transition in care has occurred for this process.
Factor 4: Beneficiary Personal Health Information
Beneficiaries and/or their caregiver(s) need access to beneficiaries’ personal
health information in order to communicate about care with healthcare
providers in other healthcare settings and/or health specialists outside their
primary care network. The organization must describe the process for ensuring
that SNP beneficiaries and/or their caregiver(s) have access to and can
adequately use personal health information to coordinate care for the
beneficiary.
Factor 5: Self-management activities
The MOC must describe how beneficiaries and/or their caregiver(s) will be
educated about their condition, how they will demonstrate understanding of
changes in their condition (improvement, stable or worsening), and use of
appropriate self-management activities. For example, they should be educated
about signs and symptoms signaling a change in their condition and how to
respond to such changes. Self-management activities can include regular
assessment of progress, goal setting and problem solving support to reduce
crises and improve health outcomes.
Factor 6: Notification of point of contact
The organization must describe the process it uses to notify beneficiaries and/or
their caregiver(s) of the personnel responsible for supporting them through
transitions between any two care settings.
MOC 3: Provider Network
The SNP provider network is a network of health care providers who are contracted to provide
health care services to SNP beneficiaries. SNPs must ensure that their MOC identifies, fully
describes and implements the following elements for their SNP provider networks.
Element A: Specialized Expertise
The organization must establish a provider network with specialized expertise that
describes the following components of the network:
1. How providers with specialized expertise correspond to the target population identified
in MOC 1.
2. How the SNP oversees its provider network facilities and oversees that its providers are
competent and have active licenses.
3. How the SNP documents, updates and maintains accurate provider information.
4. How providers collaborate with the ICT and contribute to a beneficiary’s ICP to
provide necessary specialized services.
Scoring 100% 80% 50% 20% 0%
The
organization
meets all 4
factors
The
organization
meets 3
factors
The
organization
meets 2
factors
The
organization
meets 1
factor
The
organization
meets no
factors
Explanation The organization must have an adequate and specialized provider network that
maintains the appropriate licensure and competency to address the needs of the
target population.
Factor 1: Specialized network
The provider network’s specialized expertise may include, but is not limited to,
internal medicine, endocrinologists, cardiologists, oncologists, mental health
specialists and other specialists that address the needs of the SNP’s target
population identified in MOC 1.
Factors 2 and 3: Licensure and certification
The organization must describe how it determines that its providers have active
licenses and are competent to provide specialized health care services to SNP
beneficiaries (e.g., confirmation of applicable board certification), The MOC
should describe how it maintains current information on providers to maintain
an accurate provider network directory.
Factor 4: Collaboration with the ICT/ICP
The MOC must describe how providers in the network collaborate with
members of the ICT and help contribute to each beneficiary’s ICP, including
how providers either deliver or coordinate care, particularly specialized
services. The MOC must describe how providers communicate beneficiary care
needs to the ICT and to other stakeholders or providers, how the organization
shares information (e.g., as reports on services) with the ICT and how providers
incorporate relevant clinical information into beneficiaries’ ICPs.
Element B: Use of Clinical Practice Guidelines and Care Transition Protocols
The organization must oversee how network providers use evidence-based medicine, when
appropriate, by:
1. Explaining the processes for monitoring how network providers utilize appropriate
clinical practice guidelines and nationally recognized protocols appropriate to each
SNP’s target population.
2. Identifying challenges where the use of clinical practice guidelines and nationally
recognized protocols need to be modified or are inappropriate for specific vulnerable
SNP beneficiaries.
3. Providing details regarding how decisions to modify clinical practice guidelines or
nationally recognized protocols are made, incorporated into the ICP, communicated to
the ICT and acted upon by the ICT.
4. Describing how SNP providers maintain continuity of care using the care transition
protocols outlined in MOC 2, Element E.
Scoring 100% 80% 50% 20% 0%
The
organization
meets all 4
factors
The
organization
meets 3
factors
The
organization
meets 2
factors
The
organization
meets 1
factor
The
organization
meets no
factors
Explanation Factor 1: Utilization of guidelines and protocols
Evidence-based clinical guidelines and protocols promote the use of nationally
recognized and accepted practices for providing the right care at the right time.
The organization must monitor how network providers utilize these guidelines,
when appropriate. The organization may use electronic databases, Web
technology, manual medical record review or other methods to oversee use of
clinical practice guidelines.
Factors 2 and 3: Exceptions to guidelines
Certain clinical practice guidelines and protocols may not always be
appropriate for some patients with complex health care needs. In these cases,
the organization must identify challenges to using clinical practice guidelines
and nationally recognized protocols for certain beneficiaries with complex
healthcare needs and detail how the decision to modify or ignore such
guidelines is made, incorporated into the patient’s ICP, communicated with the
ICT and acted on by the patient’s ICT or by other providers.
Factor 4: Care transition protocols
Care transitions offer challenges for organizations to maintain continuity of
care. The organization must explain how it oversees network providers to
ensure that they follow the required care transition protocols outlined in MOC
2, Element E.
Element C: MOC Training for the Provider Network
The organization’s description of oversight of provider network training on the MOC must
include:
1. Requiring initial and annual training for network providers and out-of-network
providers seen by beneficiaries on a routine basis.
2. Documenting evidence that the organization makes available and offers training on the
MOC to network providers.
3. Explaining challenges associated with the completion of MOC training for network
providers.
4. Taking action when the required MOC training is deficient or has not been completed.
Scoring 100% 80% 50% 20% 0%
The
organization
meets all 4
factors
The
organization
meets 3
factors
The
organization
meets 2
factors
The
organization
meets 1
factor
The
organization
meets no
factors
Explanation Factor 1: Initial and annual training
The MOC must describe how the organization provides initial and annual
training for network providers and any out-of-network providers seen by
beneficiaries on a routine basis; and must describe the process for annual
training for current providers, including how training is conducted (e.g., in-person meetings, computer-based training), how often training occurs, training
materials and examples of training content.
Factor 2: Evidence of training
The MOC must describe how the organization documents and maintains
records
(e.g., copies of dated attendee lists, Web-based training confirmation, electronic
training records, physician attestation) as evidence that it makes training on the
MOC available and offers it to all network providers.
Factors 3 and 4: Deficient or incomplete training
The MOC must describe specific actions taken by the organization if providers
do not receive the required training and must explain challenges (e.g.,
geographically distant network, very large number of providers in network)
associated with completion of the MOC trainings for network providers. The
MOC may also describe actions the organization takes to offer incentives or
other best practices to encourage provider training participation and
compliance.
MOC 4: MOC Quality Measurement and Performance Improvement
The goal of performance improvement and quality measurement is to improve the SNP’s ability
to deliver high-quality health care services and benefits to its SNP beneficiaries. Achievement of
this goal may be the result of increased organizational effectiveness and efficiency through
incorporation of quality measurement and performance improvement concepts that drive
organizational change.
The leadership, managers and governing body of a SNP organization must have a comprehensive
quality improvement program in place to measure its current level of performance and determine
if organizational systems and processes must be modified, based on performance results.
Element A: MOC Quality Performance Improvement Plan
The organization must develop a MOC quality performance improvement plan that:
1. Describes the overall quality improvement plan and how the organization delivers or
provides for appropriate services to SNP beneficiaries, based on their unique needs.
2. Describes specific data sources and performance and outcome measures used to
continuously analyze, evaluate and report MOC quality performance.
3. Describes how its leadership, management groups, other SNP personnel and
stakeholders are involved with the internal quality performance process.
4. Describes how SNP-specific measureable goals and health outcomes objectives are
integrated in the overall performance improvement plan, as described in MOC 4,
Element B.
Scoring 100% 80% 50% 20% 0%
The
organization
meets all 4
factors
The
organization
meets 3
factors
The
organization
meets 2
factors
The
organization
meets 1
factor
The
organization
meets no
factors
Explanation Definition
Quality measurement and performance improvement: A collaborative
process for improving an organization’s ability to deliver high-quality health
care services and benefits to SNP beneficiaries.
Factors 1–4
The organization’s MOC must describe how the quality performance
improvement plan specific to the MOC, is designed to detect whether the
overall MOC structure effectively accommodates beneficiaries’ unique health
care needs.
The MOC must describe the SNP’s process for continuous collection, analysis,
evaluation and reporting on quality performance based on the MOC. The MOC
should describe the frequency of these activities.
The MOC must provide details about how the key personnel listed in factor 3
are involved in internal quality performance processes. It should provide
information about which personnel are involved, their role in analyzing quality
performance information and the decision-making authority given to such
personnel.
The organization must specify data used for analyses, and must identify clear
measures to determine if stated goals or outcomes are achieved. Measures must
have a benchmark or goal, specify time frames for achieving outcomes and
state a plan for re-measurement if the goal is not achieved.
Element B: Measureable Goals and Health Outcomes for the MOC
The organization must identify and clearly define measureable goals and health outcomes
for the MOC and:
1. Identify and define the measurable goals and health outcomes used to improve the
health care needs of SNP beneficiaries.
2. Identify specific beneficiary health outcome measures used to measure overall SNP
population health outcomes at the plan level.
3. Describe how the SNP establishes methods to assess and track the MOC’s impact on
SNP beneficiaries’ health outcomes.
4. Describe the processes and procedures the SNP will use to determine if health outcome
goals are met.
5. Describe the steps the SNP will take if goals are not met in the expected time frame.
Scoring 100% 80% 50% 20% 0%
The
organization
meets all 5
factors
The
organization
meets 4
factors
The
organization
meets 2-3
factors
The
organization
meets 1
factor
The
organization
meets 0
factors
Explanation Factor 1
A description of measurable goals must include benchmarks, specific time
frames
and how achieving goals will be determined. Responses should include, but not
be limited to:
• Specific goals for improving access and affordability of the healthcare
needs outlined for the SNP population described in MOC 1.
• Improvements made in coordination of care and appropriate delivery of
services through the direct alignment of the HRAT, ICP and ICT.
• Enhanced care transitions across all health care settings and providers for
SNP beneficiaries.
• Ensuring appropriate utilization of services for preventive health and
chronic conditions.
Factor 2
For the stated health outcome measures, the organization must include the
specific data sources it will use for measurement. The MOC should describe
the specific measures the organization will use to meet the overall quality goals
detailed in factor 1, including expected timeframes for meeting those goals.
Factors 3&4
The MOC must describe the methods the organization uses to assess and track
how its overall quality program, including the goals and specific measures it
uses, affect the health outcomes of its beneficiaries. This may include the data
collected, how it is collected and analyzed and how often it is collected and
analyzed.
For factor 4, the MOC must describe how it determines if the goals described in
factor 1 are met.
Factor 5
The organization must describe the actions it will take if it determines that goals
are not met within the specified timeframes.
Element C: Measuring Patient Experience of Care (SNP Member Satisfaction)
The organization’s MOC must address the process of measuring SNP member satisfaction
by:
1. Describing the specific SNP survey used.
2. Explaining the rationale for the selection of a specific tool.
3. Describing how results of patient experience surveys are integrated into the overall
MOC performance improvement plan.
4. Describing steps taken by the SNP to address issues identified in survey responses.
Scoring 100% 80% 50% 20% 0%
The
organization
meets all 4
factors
The
organization
meets 3
factors
The
organization
meets 2
factors
The
organization
meets 1
factor
The
organization
meets no
factors
Explanation Factors 1–4
The MOC must describe the types of surveys used to assess SNP member
experience, the rationale for the use of a specific tool and how results are
integrated into the overall performance improvement plan.
Member feedback can include information about the overall SNP program or
program staff (e.g., ICT or case managers), the usefulness of the information
disseminated by the organization and the member’s ability to adhere to
recommendations.
Methodology. The organization must describe how it receives feedback from a
broad sample of members, not only those who contact the organization to share
feedback. Member feedback may be obtained by conducting focus groups or
through member experience surveys. The organization must describe how it
analyzes feedback to identify and address issues. Feedback must be specific to
the experience with the SNP overall programs being evaluated.
The organization must be able to describe the methodology it uses to collect
patient experience surveys, including the sample size used.
Element D: Ongoing Performance Improvement Evaluation of the MOC
The organization’s MOC description must describe:
1. How the organization will use the results of the quality performance indicators
and measures to support ongoing improvement of the MOC.
2. How the organization will use the results of the quality performance indicators
and measures to continually assess and evaluate quality.
3. The organization’s ability for timely improvement of mechanisms for
interpreting and responding to lessons learned through the MOC performance
evaluation.
4. How the performance improvement evaluation of the MOC will be documented
and shared with key stakeholders.
Scoring 100% 80% 50% 20% 0%
The
organization
meets all 4
factors
The
organization
meets 3
factors
The
organization
meets 2
factors
The
organization
meets 1 factor
The
organization
meets no
factors
Explanation Factors 1–4
The organization must provide a written description of the ongoing performance
improvement evaluation of its MOC. This process must describe how the
organization will use the results to assess and evaluate its quality performance
indicators on a continual basis, including how the organization improves its
ongoing performance by incorporating lessons learned. Lessons learned must be
documented and communicated with key stakeholders.
Element E: Dissemination of SNP Quality Performance Related to the MOC
The organization must address the process for communicating its quality
improvement performance by:
1. Describing how performance results and other pertinent information are shared
with multiple stakeholders.
2. Stating the scheduled frequency of communications with stakeholders.
3. Describing the methods for ad hoc communication with stakeholders.
4. Identifying the individuals responsible for communicating performance updates
in a timely manner.
Scoring 100% 80% 50% 20% 0%
The
organization
meets all 4
factors
The
organization
meets 3
factors
The
organization
meets 2
factors
The
organization
meets 1 factor
The
organization
meets no
factors
Explanation Factors 1–4
The organization describes how quality performance results are routinely shared
with stakeholders, and specifies the frequency of these communications and how
ad hoc and other unplanned communications are disseminated.
The organization’s plan to disseminate information must include individuals
responsible for providing communication (as described in MOC 2, Element A).
The MOC must describe methods for communication (regular and ad hoc) with
stakeholders and time frame for communication with stakeholders, who may
include, but are not limited to:
• SNP leadership.
• SNP management groups.
• SNP boards of directors.
• SNP personnel and staff.
• SNP provider networks.
• SNP beneficiaries and caregiver(s).
• The general public.
• Regulatory agencies.
History
(Rev. 117, Issued: 08-08-14, Effective: 08-08-14, Implementation: 08-08-14)
Provenance
- Source
- cms.gov
- Retrieved
- 2026-08-25
- Edition
- iom-2026-08-25
- Content hash
c40983d5f01b088b7ea99b1a166cbd20061b0dfd12968db76ce963f5801fdcea
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