Table 2IA: Completing the HRA Timeliness Impact Analysis Without Guessing
October 11, 2026
Key Takeaways
- •When CMS identifies enrollees without a timely initial or annual HRA, it can request Table 2IA during audit field work. It is due within 10 business days of the request, and submissions that do not strictly follow the record layout are rejected.
- •Columns A through G mirror your SNPE universe. The remaining columns combine HRA chronology, your Model of Care’s outreach requirements, and your outreach records.
- •The SNPE never labels an HRA as “annual.” A consistent date sequence can identify a reassessment, but some sequences cannot, and those cells should be completed from the member’s record.
- •EXC-10 does not prove an initial HRA was completed. CMS allows it when the initial HRA was completed or due more than ten years ago.
- •If your Model of Care commits to a stricter reassessment cycle than the protocol’s 365 days, state which standard each report and Column N uses. A reporting choice does not change the obligation to implement the approved Model of Care.
If CMS's timeliness testing of your SNPE universe identifies enrollees without a timely initial or annual health risk assessment, expect a request for Table 2IA, the HRA Timeliness Impact Analysis (HRAT-IA). It is an impact analysis requested during field work, separate from the universe package. It is due within 10 business days of the request, and CMS rejects submissions that do not strictly adhere to the record layout. Ten business days is a short window to reconstruct outreach history, so it pays to decide in advance how each column will be filled.
This post walks through the layout, separates what your universe can supply from what only your records can, and covers three situations that need particular care. Sources are the SNPCC Program Audit Protocol and Data Request in the CMS-10717 package (ZIP), the CMS audit protocol FAQ (PDF) and 42 CFR 422.101(f). The official record layout governs; treat this post as a companion to it, not a substitute.
Who Belongs on the Table, and Which Event to Report
Two different boundaries are easy to blur.
The timeliness tests have their own populations. The initial HRA test (Standard 1.1) covers current enrollees continuously enrolled at least 90 days whose enrollment effective dates fall within 12 months of the engagement letter. The annual test (Standard 1.2) covers enrollees continuously enrolled 365 days or more, plus newer enrollees who missed the initial HRA deadline. The annual test has no recent-enrollment cutoff, so long-tenured members stay in it.
The impact analysis has a separate 12-month review period: enrollees who did not receive a timely initial or annual HRA within the 12 months before the engagement letter date, as specified in CMS's request. When a member has more than one HRA event in that period, follow the instruction to report the most recent HRA event that occurred during that timeframe. Copying the latest pair of dates from the SNPE without checking which event falls in the period can report the wrong one.
Reconcile the two before you submit. As a plan control, your untimely SNPE population, scoped to the same review period, should line up with your Table 2IA rows, and any member who does not should have a documented reason.
What Your SNPE Supplies, and What It Cannot
| Column | Content | Source |
|---|---|---|
| A to G | First name, last name, MBI, contract, PBP, SNP type (D-SNP, C-SNP or I-SNP), and the effective date of the most current continuous enrollment | Mirror the SNPE universe |
| H | Actual initial HRA completion date, or NA if not completed | SNPE Column K when it holds a valid date; otherwise verify from member records. Never copy None or EXC-10 into H |
| I | Initial HRA outreach attempts required | Your Model of Care in effect at enrollment |
| J | Initial HRA outreach attempts made | Outreach records (0 when none) |
| K, L | First and last initial HRA outreach dates | Outreach records |
| M | Initial HRA refusal date, or NA if no refusal | Outreach records |
| N | Annual HRA due date for the reported event (a date, even when the deadline is in the future) | Calculated from the applicable prior HRA, or enrollment when no initial HRA was conducted |
| O | Annual HRA completed: Y (yes), N (no) or NA (annual HRA not yet due) | HRA records |
| P | Annual HRA completion date, or NA if not completed | HRA records |
| Q | Annual HRA outreach attempts required | Your approved Model of Care at the time of the outreach |
| R | Annual HRA outreach attempts made | Outreach records (0 when none) |
| S, T | First and last annual HRA outreach dates, or NA if no attempts were made | Outreach records |
| U | Annual HRA refusal date, or NA if no refusal | Outreach records |
| V | Date the latest Unable to Contact letter was sent, initial or annual, or NA if none was sent | Records (FAQ Q66) |
A few conventions decide whether the file is accepted:
- Zero versus blank versus NA. For initial outreach, zero attempts means J = 0 with K and L left blank, and a single attempt means the same date in K and L (FAQ Q65). For annual outreach, zero attempts means R = 0 and NA in S and T. Do not substitute a blank or NA for a zero count. And "no refusal" is a fact from your records; missing documentation is not the same thing.
- Lengths and formats. Keep the CMS column order and check every field against the official layout. Names allow 50 characters, the contract ID is 5, the MBI is 11 uppercase letters and numbers without hyphens, and the PBP keeps all three characters, including leading zeros. Dates are CCYY/MM/DD. The attempt counts in I, J, Q and R are numeric counts in fields of up to two characters; a single-digit count such as 0 or 3 needs no padding. The protocol accepts .xlsx with a header row or .txt without one.
- Completion means returned. For the initial HRA, CMS defines the completion date as the date the completed HRA is returned to the organization by the enrollee or representative. An outreach or scheduling date is not a completion date.
Your Model of Care count in Columns I and Q is not the only outreach standard in play. Under 42 CFR 422.101(f)(1)(iv), plans must make at least three attempts to reach the enrollee, not counting automated calls, on different days at different times of day, unless the enrollee agrees or declines to participate in the HRA before three attempts are made. If the enrollee has not responded, the plan must send a follow-up letter. For enrollees who cannot be reached or who decline, the plan must document the attempts and, where applicable, the enrollee's choice not to participate.
Three Situations That Need Care
1. Which HRA was the annual one
The SNPE carries three HRA dates. Column I is the most recent completed HRA, or None if none was completed. Column J is the most recently completed HRA preceding I, or None when no earlier HRA was completed; if the only HRA is the initial one, I holds its date and J is None (FAQ Q60). Column K is the initial HRA date, None when no HRA was completed within 90 days before or after enrollment, or EXC-10. None of these columns says "annual." A consistent sequence, such as a timely initial HRA followed by a later reassessment, can identify one. Some sequences cannot. One example: K and J are None, and I holds a single date more than 90 days after enrollment. That HRA could be a late initial assessment or a reassessment, and the universe alone does not say which. Classify it from the member's record before completing H and Columns N through P.
2. EXC-10
EXC-10 is permitted only in SNPE Column K. It suppresses the initial HRA date when that HRA is more than ten years old, and per CMS FAQ Q59 it can be used when the initial HRA was due more than ten years ago, whether or not one was completed. So EXC-10 is not evidence of completion, and it never belongs in Table 2IA Column H, which accepts an actual date or NA. It is also not an exclusion from reassessment: the annual requirement still applies. Columns I and J may still support the annual due date; where they do not, review the member's reassessment history.
3. Annual HRAs not yet due
When the applicable annual HRA was not yet due and had not been completed, enter its due date in N and NA in O and P. An annual HRA completed early is a different case. O lists Y for a completed annual HRA and NA for one not yet due, and P's NA applies only when the HRA was not completed, so the field descriptions alone do not settle the combination. Confirm which annual event CMS is requesting and clarify the O and P values with the audit team. For outreach, if no annual outreach or refusal occurred, enter R = 0 and NA in S, T and U, with Q still showing the required count. A future due date is not evidence that no outreach happened; that statement has to come from your records, and confirming it is a verification step worth assigning to a named person.
The Model of Care Question
The protocol tests annual reassessment within 365 days of the prior HRA completion date, or of enrollment if no initial HRA was conducted. For illustration, suppose your approved Model of Care commits to reassessment within 364 days of the last assessment. Which number drives Column N?
The protocol specifies the 365-day test but does not expressly address Column N when an approved Model of Care sets a stricter deadline. That silence is not permission to pick any deadline, and it does not change your obligation under 42 CFR 422.101(f) to implement the approved Model of Care. Document the basis you use for Column N, resolve any uncertainty against CMS's request, and clearly identify the standard used in each internal report. A due date that changes between reports without explanation is the outcome to avoid.
Keep Auxiliary Work Outside the Submission
Every value in Table 2IA must satisfy the requested scope, the field's meaning and its permitted values. Some of those values are calculated, Column N most obviously, and belong in the file once confirmed. Auxiliary work does not: proposed classifications, ambiguity flags, intermediate date math and notes. Keep that material outside the Table 2IA submission and retain it as supporting documentation, so you can show the source and logic behind any value if asked.
Sevana's CMS Universe Scrubber generates a Table 2IA from your validated SNPE file with the latest data-as-of date, once its timeliness calculation is complete. It copies SNPE values, uses the source file's configured annual timeframe for generated due dates, fills values the layout defines and entries your team confirms, and leaves unresolved cells for your team. An optional confirmation fills Columns N, O and P for eligible annual HRAs due by the review-period end; ambiguous dates, EXC-10 rows and completion dates after that end remain for manual completion. Before relying on the generated population, review the source file's findings and any members the page lists for review. Auxiliary calculations stay out of the submission file. Upload the completed .xlsx file as HRAT_IA to run validation checks, then review the findings against your records and CMS's instructions. Never replace documented completion or outreach information with a zero or NA just to clear a finding.
The Honest Summary
Table 2IA combines HRA chronology, Model of Care requirements and outreach evidence. It must meet the record layout, and CMS may verify the data behind it. Four things are worth settling early: which HRA event you report for the review period, how you handle EXC-10 and ambiguous date sequences, the zero, blank and NA conventions, and which standard drives the annual due date. Settling those before the request arrives leaves more of the 10 business days for gathering outreach evidence. For the broader protocol, see our SNPCC compliance guide and the SNPCC quick reference.
Scope note. This post summarizes the Table 2IA record layout and related CMS guidance as published. It is not a CMS compliance determination, and CMS cautions that its audit protocols and record layouts should not be used on their own to interpret policy; see the CMS Program Audits page.
Reviewed against the CMS-10717 SNPCC Program Audit Protocol and Data Request (OMB 0938-1395, expiring January 31, 2027), the CMS audit protocol FAQ of February 27, 2023, and 42 CFR 422.101(f), October 2026.
Frequently Asked Questions
When is Table 2IA due?
Table 2IA, the HRA Timeliness Impact Analysis, is requested during audit field work when CMS identifies enrollees without a timely initial or annual HRA. It is due within 10 business days of the request, separate from the universe package, and submissions that do not strictly adhere to the record layout are rejected.
What goes in the outreach date columns when no attempts were made?
For initial HRA outreach, CMS FAQ Q65 says to leave the first and last attempt dates (Columns K and L) blank when no attempts were made, with Column J set to 0, and to enter the same date in both when only one attempt was made. For annual HRA outreach, zero attempts means Column R is 0 and Columns S and T are NA.
Can EXC-10 be entered in Table 2IA Column H?
No. EXC-10 is permitted only in SNPE Column K. Table 2IA Column H accepts the actual initial HRA completion date or NA if it was not completed. Because CMS FAQ Q59 allows EXC-10 when the initial HRA was due more than 10 years ago, EXC-10 does not by itself prove an initial HRA was completed; verify from member records.
Which Unable to Contact letter goes in Column V?
Per CMS FAQ Q66, Column V captures the date of the latest available HRA Unable to Contact letter, initial or annual, that was sent to the non-responding enrollee, or NA if none was sent.
Which timeframe drives the annual HRA due date in Column N if our Model of Care is stricter than 365 days?
The SNPCC protocol tests annual reassessment within 365 days of the prior HRA completion date, or of enrollment if no initial HRA was conducted, and does not expressly address Column N when an approved Model of Care sets a stricter deadline. That silence does not change the obligation under 42 CFR 422.101(f) to implement the approved Model of Care. Document the basis used for Column N, resolve uncertainty against CMS's request, and identify the standard used in each internal report.
Start Table 2IA From Your SNPE
See how a validated SNPE file becomes a Table 2IA draft, pre-filled only where the universe and the layout support it, with the rest left for your team.