AHCA/NCAL has highlighted some additional details regarding the Contract Year 2022 Medicare Advantage and Part D Final Rule (CMS-4190-F2). The rule codifies a number of long standing program changes introduced through previous guidance and communications. It also introduces a number of new changes. Most noteworthy are the new requirements for Special Needs Plans (SNPs). Previously, the new requirements applied only to Chronic Condition Special Needs Plans (CSNPs). But the new rule extends the requirements to include all SNPs.
New provisions to include:
- Requirement for interdisciplinary care team (ICT) to include providers with demonstrated experience in the applicable specialty.
- Provision of face to face encounters by a member of the ICT with every member at least annually. Face to face includes in-person or through visual real-time, interactive telehealth encounters.
- The results of the initial assessment and annual reassessment required for each member must be addressed in the member’s individualized care plan.
- Evaluation and approval of model of care (MOC) must take into account whether the plan fulfilled the previous MOC’s goals.
- Plans must provide relevant information/data to support fulfillment of previous MOC’s goals.
- New MOCs must provide relevant information pertaining to MOC’s goals for review and approval.
- If the SNP MOC did not fulfill the previous MOC’s goals, the plan must indicate in the MOC submission how it will achieve or revise the goals for the plan’s next MOC.
- Added requirement for scoring benchmarks to be met for MOC to be approved. The Secretary will establish a minimum benchmark for each element of the MOC, and an MOC can only be approved if each element meets the minimum benchmark.
The majority of the changes are activities that Institutional Special Needs Plans (ISNPs) already engage in. Whether these changes will have a larger impact remains to be seen and will be based on the detailed interpretation by CMS around each element.