CMS Shifts SNP Model of Care (MOC) Deadline for 2027

CMS just announced a major change that will affect all Special Needs Plans (SNPs) beginning with Contract Year (CY) 2027.

Starting in 2027, SNPs must submit their Models of Care (MOCs) by the Friday before the first Monday in June, aligning the MOC deadline with Medicare Advantage bid submissions and State Medicaid Agency contracting. For CY2027, that date is May 29, 2026.

And don’t forget: the Notice of Intent to Apply (NOIA) is still due in November 2025. That means plans must start strategic planning well in advance of both the NOIA and MOC deadlines.

Why This Matters

• Bids may now be filed before MOC approval placing pressure on getting the MOC right the first time.

• Tighter turnaround for revisions if CMS or NCQA requests changes.

• Operational timelines may shrink, risking delays in implementation and readiness if submissions are late.

CMS has noted that this shift is based on plan and state feedback, aiming to streamline processes. 

The Bottom Line

SNPs should begin recalibrating internal calendars now. With the NOIA in November 2025, the application in February 2026 and the MOC deadline in May 2026, the window for preparation is tight. This timeline shift will ripple across compliance, quality, clinical, and operational teams — making early readiness essential.

How Rebellis Can Help

At Rebellis Group, we are partnering with health plans to assess whether a C-SNP is the right strategic move — and to prepare organizations for launches under evolving CMS requirements.

Our Market Assessment and Readiness Analysis includes:

• Feasibility Study

• Operational & Clinical Readiness

• Design & Execution Planning

  
  

Whether you are just exploring a C-SNP or preparing for CY2027, Rebellis helps ensure decisions are informed, realistic, and actionable.