CMS-SNP Guidance

Special Needs Plans must comply with all Medicare Advantage rules except where the law provides for variance or CMS has the authority to modify rules.  Key differences between SNPs and standard MA plans include the following: 

• SNPs can limit enrollment to targeted special needs individuals.
• Dually eligible and institutionalized beneficiaries may enroll and disenroll throughout the year.
• Beneficiaries who qualify for a chronic condition SNP have a one-time enrollment option outside of standard enrollment periods.
• SNPs integrating Medicare and Medicaid benefits may target enrollment to certain subsets of dual beneficiaries.
• All SNPs must offer Part D coverage.

CMS issued Final MA Special Needs Plan Guidance in January of 2006 to clarify differences in regulatory requirements and operational policies between standard MA plans and SNPs.  Since the Final SNP Guidance was released, CMS has continued to work with SNPs and states to refine SNP policies in areas such as enrollment, marketing, quality and dual subsets for SNPs integrating Medicare and Mediciaid.  CMS also developed a detailed action plan for developing SNP-specific performance measures.  It issued a series of new SNP initiatives in July, including new guidance on integrated Medicare and Medicaid models.  Additional guidance on subset policies has been provided. 

It is anticipated that CMS will update the January 2006 SNP Guidance in the future to be consistent with evolving operational policies.