Crosswalk

New This represents new requirements legislated
by the BBA of 2018 to section 1859(f) of the
Social Security Act.

New SNP MOC Requirement

New SNP MOC Requirement
MOC Element 2B Care Coordination: HRAT
A description of how the SNP ensures that the results
from the initial HRAT and the annual reassessment
HRAT conducted for each individual are addressed in
the individual’s care plan.

New SNP MOC Requirement

New This represents new requirements legislated
New SNP MOC Requirement
MOC Element 2C Care Coordination: Face-to-Face
by the BBA of 2018 to section 1859(f) of the
Encounter
Social Security Act.
A face-to face encounter must be conducted between the
SNP and each consenting enrollee no less than on an
annual basis. Face-to-face encounters can be conducted inperson or through remote technology, such as telehealth,
and must occur within the first 12 months of enrollment.

New SNP MOC Requirement

New SNP MOC Requirement
MOC Element 3A SNP Provider Network: Specialized
Experience
The description must include evidence that the SNP
provides each enrollee with an interdisciplinary team that
includes providers with demonstrated experience and
training in the applicable specialty, or area of expertise,
in treating individuals that are similar to the target
population.

Page 1 of 2

New This represents new requirements legislated
by the BBA of 2018 to section 1859(f) of the
Social Security Act.

Burden Change

Reason for Change

Type of Change

2020 (new version)

2019 (Current
version)

CMS-10565, OMB 0938-1296
Attachment B – Revised Model of Care Matrix Upload Document (Off-Cycle Revisions)
Crosswalk

Budget Neutral
This requirement is
consistent with
currently approved
information tracking
practices & does not
impose any new or
revised burden beyond
what is currently
approved by OMB.
Increased burden for
SNPs.

Budget Neutral
This requirement is
consistent with
currently approved
information tracking
practices & does not
impose any new or
revised burden beyond
what is currently
approved by OMB.

CMS-10565, OMB 0938-1296
Attachment B – Revised Model of Care Matrix Upload Document (Off-Cycle Revisions)
Crosswalk
Current MOC Requirement
MOC Element 4B Quality
Measurement and
Performance Improvement:
Measurable Goals & Health
Outcomes for the MOC

Rev This represents new requirements legislated
by the BBA of 2018 to section 1859(f) of the
MOC Element 4B Quality Measurement and Performance
Social Security Act.
Improvement: Measurable Goals & Health Outcomes for
the MOC
New SNP MOC Requirement

If the MOC did not fulfill the previous MOC’s goals, the plan
must describe how it will achieve or revise the goals for the
plan’s next MOC implementation.

Explain the specific steps the
SNP will take if goals are not
met in the expected time frame. Note that we are eliminating the current requirement to
“Explain the specific steps the SNP will take if goals are not
met in the expected time frame” and replacing it with “If the
MOC did not fulfill the previous MOC’s goals, the plan must
describe how it will achieve or revise the goals for the plan’s
next MOC implementation.”
Bothe the existing and new requirement are somewhat
similar in nature, however, the new requirement mandated
by the BBA is more specific and requires SNPs to describe
how it will achieve or revise the goals for the plans next
MOC implementation. Therefore, we’re eliminating the
existing MOC requirement identified in the left column.

Page 2 of 2

Budget Neutral
This requirement is
consistent with
currently approved
information tracking
practices & does not
impose any new or
revised burden beyond
what is currently
approved by OMB.