Thursday SNaP Shot from SNP Alliance | |
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SNP Alliance Updates
- President & CEO Monthly Membership Message
- Policy Developments - Legislation and Regulatory
- News and Market Developments
- Research
- SNP Alliance Organizational Updates
- Reaching SNP Alliance Team Members
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President & CEO
Monthly Membership Message
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SNP Alliance Members,
While Spring is a busy time of year, each year, this year has been unusual with an array of Requests for Information (RFIs) and a challenging Advance Notice. As of today, our NPRM remains at the Office of Management and Budget (OMB) for review. We anticipate release the week before our Spring Meeting (April 16–17) or early the week of our meeting. We will be watching for any sort of response to the RFI feedback.
CMMI is leading on most of the RFIs and the federal government is not required to respond to RFI input. However, it is possible CMS might include some commentary indicating “we are contemplating future policymaking based on RFI input …” This is conjecture but worth noting. The SNP Alliance has meetings with CMMI scheduled on our RFI submissions.
Regarding the Advance Notice, which also still is at OMB, the SNP Alliance continues to message the White House and CMS, as well as the Hill, about challenges. A succinct one-page document was sent to the White House, the CMS Office of the Administrator, and CMS Senior Career staff. To-date, 12 Hill meetings have been held on the Advance Notice challenges with more to come.
We also are monitoring CMMI for additional demonstration information. In particular, we anticipate the release of the LEAD ACO Request for Participation Application (RPA) near the end of March or in early April. The SNP Alliance team will be working with the membership to understand the dynamics of SNPs and LEAD ACOs and will provide member guidance.
As always, thank you for your participation in the SNP Alliance community and please feel free to reach out to me, directly, or any SNP Alliance team member for support – technical or for guidance on how best to leverage your membership.
Best Regards,
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Michael W. Cheek
President & CEO
Special Needs Plan Alliance
1666 Connecticut Ave. NW, Suite 250
Washington, D.C. 20009
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Policy Developments
Legislation and Regulatory
| | On March 17, the Energy & Commerce Oversight & Investigations Subcommittee held a hearing titled Protecting Patients and Safeguarding Taxpayer Dollars: The Role of the Centers for Medicare & Medicaid Services (CMS) in Combatting Medicare and Medicaid Fraud. The hearing covered the Trump Administration’s efforts to address fraud in Medicare and Medicaid, as well as common fraud schemes and program vulnerabilities. | | | On March 18, the Energy & Commerce Health Subcommittee held its third hearing on health care affordability titled Lowering Health Care Costs for All Americans: An Examination of the U.S. Provider Landscape. The hearing covered the role that provider payment policies, competition, transparency, the 340B program, and other incentives shape patient access and the cost of care. | | | Senator Cassidy (LA-R) is leading development of a co-sign letter urging CMS to move forward with specific provisions of the Advance Notice. The letter also notes CMS should exercise its current authority to take action on provisions which previously appeared in the NO UPCODE legislation. | | | As of March 25, the Advance Notice remains at OMB and is required to be promulgated the first Monday in April – April 6 of this year. The SNP Alliance has scheduled an All Member Webinar on the Final Rate Notice for April 8, 3:00 – 4:00 EST. The Webinar will be recorded and posted in our Members’-Only Section. | | | |
As of March 25, the Final Rule is expected in April. The SNP Alliance will produce a summary as well as schedule an All-Member Webinar which will be education and, during which, the Staff also solicit member requests for technical assistance.
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As of March 25, Medicaid Managed Care State Directed Payments and Medicaid Fee-For-Service Targeted Medicaid Practitioner Payments (CMS-2449) remains at OMB under Review.
| | | On March 20, CMS released the Payment Year 2020 Medicare Advantage Contract-Specific Risk Adjustment Data Validation (RADV) Methods and Instructions. To view a table showing the differences between the 2019 and 2020 methods, click here. | | | On March 19, CMS released a readout of its first Rural Health Transformation Summit, which convened leaders from all 50 states on March 18 to support implementation of the Rural Health Transformation Program. The summit focused on state-led strategies to expand access to care, strengthen the rural health workforce, advance value-based care models, and modernize health infrastructure under the $50 billion initiative. CMS indicated that the meeting marked the launch of an ongoing learning collaborative to support coordination, technical assistance, and best practice sharing across states. | | | On March 20, CMS issued a final rule titled Administrative Simplification; Adoption of Standards for Health Care Claims Attachments Transactions and Electronic Signatures. The rule establishes national standards for the electronic exchange of clinical documentation supporting health care claims and for electronic signatures, replacing manual processes such as fax and mail. CMS estimates the rule will save approximately $781.98 million annually. Compliance with the new requirements is required by May 26, 2028. A fact sheet can be found here. | | | On March 13, CMS’ Innovation Center released a notice of funding opportunity for the MAHA ELEVATE model, which will select up to 30 cooperative agreement recipients, including three focused on dementia and cognitive decline. The model will provide up to $3.3 million per recipient over a three-year period, with total funding of up to $100 million, and will condition payments on meeting operational and enrollment milestones. Letters of intent are due by April 10, and applications for the first cohort are due by May 15, with a second cohort to be announced at a later date. | | | CMMI has released guidance on its BALANCE initiative. To view a SNP Alliance overview with SNP-specific observations, click here. | | | As of March 25, the LEAD ACO RPA has not been released. We anticipate release in late March or early April. For more information on LEAD, click here. | | | |
The SNP Alliance now has the capacity to track state-level legislation. Trends to-date in state-level legislation include provider rate cuts and changes in capitation rates.
| | | Of note, some State Legislatures and Governors are pressing CMS for authority to regulate MA. These states have appeared in the SNP Alliance state tracking. Under federal law, states have no authority to regulate MA. The SNP Alliance does not anticipate CMS ceding any ground to states in this area. | | | Rand Corporation has completed an analysis of publicly available data, published literature, state and federal agency reports, and other sources of information to develop customized approaches to build state-level estimates through 2034 of Medicaid budget impact and enrollment changes associated with several key provisions of the One Big Beautiful Bill (OB3). In the report, Rand describes our detailed, state-level estimates of the budgetary effects of many of OB3's key Medicaid provisions for each state. Although prior studies have allocated the CBO’s estimate across states, Rand developed most of their estimates independently from the CBO scores, often using state-specific source material and data. View supporting article here. | | | News and Market Developments | | |
On March 12, Microsoft announced the launch of Copilot Health, a health-focused artificial intelligence tool designed to help users interpret personal health data and generate personalized insights. The platform integrates electronic health records, wearable device data, and other health information sources to support users in understanding their health and preparing clinical visits.
| | | On March 19, Milliman released an I-SNP Market study. Milliman presented on the brief during the SNP Alliance’s I-SNP work group meeting held on March 18. To view the meeting recording click here to access the I-SNP Work Group virtual workspace. | | | |
While older, in January 2026, Milliman released a brief laying out key questions health care provider organizations should evaluate when considering LEAD. The document likely is worth reviewing in light of the pending RPA release.
| | | On March 12, MedPAC released its March Payment Report to Congress. Chapter 15 contains is statutorily required D-SNP report update. This document discusses the performance, challenges, and policy considerations related to Medicare Medicaid dual-eligible special-needs plans and integrated care programs for dually eligible beneficiaries. The Chapter contains a wide range of topics. Highlights include challenges with D-SNP performance evaluation, a discussion of 2027 and 2030 regulatory requirements, and the implications of C-SNP growth. To view a SNP Alliance summary, click here. | | | |
C-SNP Workgroup Meeting - C-SNPs have grown rapidly among the dual-eligible population. Dual-eligible enrollment into C-SNPs and other non-integrated MA plans increased significantly in counties with terminated look-alike plans, compared to control counties without look-alike plans. Researchers discuss this trend may be compromising enrollment into MA products that coordinate and integrate care for dual-eligible individuals and outline potential policy considerations to address these concerns. View supporting document here.
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SNP Alliance
Organizational Updates
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Defining the Critical Role of Special Needs Plans Growing Demand with High Quality Services
We're excited to invite you to join us for the SNP Alliance Spring Members-Only Roundtable, taking place April 16th & 17th, 2026 in Washington, DC at the Yours Truly Hotel. This year's meeting brings our community together in a focused, collaborative setting to dive deep into the evolving policy landscape and share insights on strategies that strengthen SNPs' Value. Please click the links below for registration and to learn more about our upcoming Spring Roundtable. If you have any questions, please contact Sam Amaya at samaya@snpalliance.org. Please note the hotel reservation deadline is March 31st!
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Day 1
During the April members-only meeting, the membership will hear from CMS officials and experts in complex chronic care about policy and practices strengths, weaknesses, opportunities and threats during day one. Each panel will conclude with a concrete set of action steps for plans and SNP Alliance policy development as well as advocacy.
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Day 2
During the second day, April 17, based upon the expert panels, the membership will develop, or refine, SNP Alliance policy and strategy as well as identify needed technical assistance resources. The discussion will focus upon expanding SNP Request of Information responses, broad positioning strategies with CMS divisions, as well as CMMI, and proactively addressing unfolding Congressional policy discussions.
| | Reaching SNP Alliance Team Members | | | Mike Cheek
President & CEO | mcheek@snpalliance.org | | Vicky King
Director of Operations | vking@snpalliance.org | | Matthew McLarnon
Integration Policy Manager | mmclarnon@snpalliance.org | | Regan Hunt
Associate Director of Policy | rhunt@snpalliance.org | | Kathleen Henry
Administration | khenry@snpalliance.org | | Samuel Amaya
Associate Manager of Member Services | samaya@snpalliance.org | | TA Center | TACenter@snpalliance.org | | | The Special Needs Plan Alliance (SNP Alliance) issues a monthly newsletter with original content tailored to the SNP community developed by the SNP Alliance policy team and membership. If you have questions on, or suggestions for, newsletter content, please contact Mr. Sam Amaya at samaya@snpalliance.org. | | | | |