Protocol Reference · Part of the CMS Program Audit Guide
The SNPCC Protocol: SNPE Universe, Standards, and Failure Modes
SNPCC (Special Needs Plans Care Coordination) is how CMS verifies that a Special Needs Plan delivers on its Model of Care commitments: timely health risk assessments, individualized care plans that actually operate, and care teams that coordinate. This page is the working reference.
Who SNPCC Applies To
D-SNP
Dual eligible: members enrolled in both Medicare and Medicaid.
C-SNP
Chronic condition: members with specific severe or disabling chronic conditions.
I-SNP
Institutional: members in institutional settings or requiring an institutional level of care. See our I-SNP compliance page for the operator-specific view.
What the Submission Includes
SNPE
SNP Enrollees (the universe table)All current enrollees with required fields including enrollee identifiers (name, MBI), contract and PBP, plan type, HRA completion dates, risk stratification level, and ICP date and ICT status. Due 15 business days from the engagement letter.
Models of Care
Supplemental submissionThe approved MOCs the SNP team lead identifies for submission. Due 5 business days from the engagement letter.
SNPCC Questionnaire
Supplemental submissionThe protocol questionnaire, also due 5 business days from the engagement letter. The 5-day supplemental deadlines are the earliest hard dates in the audit and catch teams that plan around the 15-day universe window.
The 13 Care Coordination Standards
CMS evaluates SNP care coordination through 13 standards, grouped into four themes:
Standards 1.1 to 1.2
HRA timelinessInitial HRA within 90 days of enrollment; annual HRA within 365 days of the previous HRA. Tested at the universe level, every enrollee, with impact analysis required for untimely cases.
Standards 1.3 to 1.7
Care plan qualityThe HRA addresses comprehensive needs; the individualized care plan (ICP) has measurable outcomes and timeframes, gets reviewed as needs change, is verifiably implemented, and involves the enrollee or caregiver.
Standards 1.8 to 1.10
Care team effectivenessCoordinated communication among the interdisciplinary care team (ICT), appropriate disciplines including the PCP on the team, and care transition protocols that maintain continuity.
Standards 1.11 to 1.13
Staff qualifications and trainingStaff meet the professional requirements the Model of Care commits to, ICT members receive MOC training, and network providers receive MOC training.
Where SNPCC Compliance Fails
- •Annual HRA timeliness measured from the wrong anchor. The 365-day clock runs from the previous HRA, not the enrollment date. Measuring from enrollment makes late members look on time until case files are pulled.
- •Hard-to-reach enrollees with undocumented outreach. Every untimely HRA requires an impact analysis showing outreach attempts. Attempts that happened but were never logged with dates and methods do not exist for audit purposes.
- •Care plans that exist but do not operate. ICPs without measurable outcomes or timeframes, no evidence of member or caregiver involvement, and no linkage between HRA-identified needs and interventions.
- •Care transitions that bypass the care team. Hospital discharges with no ICT notification, no ICP update, and no medication reconciliation are where members fall through the cracks and where auditors look first.
- •SNPE data quality. HRA dates inconsistent with the underlying assessments, cross-field logic failures (an initial HRA date outside 90 days of enrollment with no impact analysis ready), MBI format errors, and dates not in CCYY/MM/DD. Data problems become IDS findings here the same as in every other universe.
Go Deeper
- •The full SNPCC compliance guide covers all 13 standards, the audit timeline, and impact analysis requirements in detail.
- •I-SNP compliance looks at SNPCC readiness from the perspective of institutional SNP operators with small compliance teams.
- •The free Universe Header Check tool validates your SNPE file headers against the current CMS spec in your browser.
Frequently Asked Questions
Which plans are subject to a SNPCC audit?
All three Special Needs Plan types: D-SNPs (dual-eligible members), C-SNPs (members with specific severe or disabling chronic conditions), and I-SNPs (members in institutional settings or requiring an institutional level of care). If a sponsor operates any SNP, SNPCC is in scope when CMS audits it.
What does the SNPCC universe submission include?
One universe table, SNPE (SNP Enrollees), listing all current enrollees with required fields including identifiers, contract and PBP, plan type, HRA completion dates, risk stratification, and ICP and ICT status. Two supplemental submissions accompany it: the approved Models of Care the SNP team lead identifies, and the SNPCC Questionnaire. The universe gets 15 business days from the engagement letter; the MOC and questionnaire are due in 5.
When are initial and annual HRAs due?
The initial health risk assessment is due within 90 days of enrollment, and each annual reassessment is due within 365 days of the previous HRA. The annual clock runs from the prior HRA, not from the enrollment anniversary. Measuring it from the enrollment date is the classic error that makes late members look on time until auditors pull case files.
How does CMS test SNPCC compliance during fieldwork?
CMS tests HRA timeliness across the whole universe rather than a sample, selects cases for a pre-fieldwork integrity webinar, and then reviews roughly 30 enrollees in depth: HRAs, ICPs, case management documentation, claims, ICT credentials, and MOC training evidence. Supporting documentation requests during fieldwork carry a 2-business-day response window, and identified noncompliance triggers impact analyses due within 10 business days.
Validate Your SNPE Universe Before CMS Does
The CMS Universe Scrubber checks SNPE files against the CMS record layout: field formats, HRA timeliness logic anchored to the right dates, and cross-field consistency.