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If your Model of Care submission is still built around “compliant enough” but is light on how you operationally execute in alignment with requirements, the 2026 standards will expose that disconnect. CMS and NCQA haven’t overhauled the four MOC standards—but they have raised the bar significantly on what it means to actually meet them. We’re talking data currency, analytic rigor, operational discipline, and airtight documentation. The message from NCQA is clear: intent is no longer enough.

We’ve seen this situation many times at MHR: organizations that did the work, put in the hours, and wrote a solid MOC—but their documentation didn’t reflect how care is actually delivered. That gap between intent and execution is exactly what the 2026 updates are designed to surface. 

Use this blog as your gut-check. Whether your submission is already drafted or you’re still in planning mode, walk through these updates and validate that what you’ve written can hold up under scrutiny. If it can’t, now is the time to refine it.

The Framework Hasn’t Changed—But the Expectations Have

The MOC continues to be evaluated across four standards and 16 elements, with scoring based on 64 total points and required minimum thresholds at both the element and overall score levels. Approval periods remain tied to performance tiers, and Chronic Condition SNPs (C-SNPs) are still limited to one-year approval regardless of score.

What has shifted is how rigorously NCQA expects plans to demonstrate execution—not just describe it.

 What’s Actually Different in 2026 

 1. Your Data Has to Be Current, Plan-Specific, and Analytically Defensible

This one affects MOC 1A, 1B, and MOC 4 in particular.

NCQA is explicit: 

• Data may not predate 2021. 
• Plans renewing after year two must use their own historical data—not proxy datasets, not national benchmarks, and not local statistics unless they are explicitly correlated to your enrolled population.
• National data may only be used if explicitly correlated to the plan’s enrolled population.

The bottom line: boilerplate population narratives and generic statistics will not score well without a clear, documented connection to your specific plan’s enrolled or intended members. If your MOC still relies on borrowed data to tell its story, that’s a scoring risk you need to address now.

 2. “Most Vulnerable” Has to Mean Something Operational

MOC 1B received significant tightening. NCQA now expects plans to define and document:

• The criteria used to define vulnerability, 
• How demographic characteristics directly affect health outcomes, 
• The relationship between vulnerability, clinical needs, and tailored services,
• Explicit details on community partners or systems used to access them

The bottom line: describing vulnerability in theory won’t cut it. Your MOC needs to show how vulnerability is identified in practice and what your organization actually does about it.

 3. Care Coordination Has to Flow End-to-End—and Be Provably Operational

MOC 2 clarifications place new emphasis on process flow and accountability. What does that look like in practice? The updated NCQA standards now require:

• Inclusion of organizational charts that identify staff responsible for care coordination, 
• Explicit contingency planning for staff turnover, 
• Detailed training documentation with remediation processes, and 
• Clear linkage between HRAs, risk stratification, ICP development, and ICT composition.

The bottom line: a tightly integrated care coordination infrastructure—not siloed processes—is the expectation. If your MOC describes components but doesn’t connect the dots, that’s a problem.

 4. HRAs Are Active Drivers of Care—Not Passive Documentation Tools

For 2026, NCQA strengthened the expectation that HRAs are not static tools but active drivers of care. 

• HRAs must feed directly into ICP development and updates. 
• Plans must describe how HRA data are stratified, analyzed, and communicated. 
• Stratification results must clearly inform ICT composition and care planning.

The bottom line: if your HRA process is disconnected from care planning, ICT operations, or quality measurement, it is a scoring risk. The HRA isn’t just a form—it’s the engine. Make sure your MOC reflects that.

5. Quality Improvement Has to Close the Loop

MOC 4A and 4B continue to be common failure points, and NCQA explicitly cautions plans to review these elements carefully. 

Plans must now demonstrate:

• Analysis of previous MOC goals, 
• A clear determination of whether goals were met, 
• Defined corrective actions and remeasurement when goals are not achieved, and 
• Measurable outcomes tied to ICP, HRA, and ICT completion (set at 100%).

The bottom line: aspirational goals without documented evaluation and follow-through will not meet expectations. The loop has to close. If you set a goal, NCQA expects to see what happened next.

How to Prepare: Five Areas That Need Your Attention Now

 1. Re-Validate All Population Data

•       Confirm all demographic, health status, and disparity data are current (2021 or later)
•       Replace proxy data with plan-specific analytics wherever required
•       Explicitly differentiate your general population from your “most vulnerable” population

2. Stress-Test Care Coordination Workflows

•       Map the flow from HRA → stratification → ICP → ICT → care transitions
•       Validate that documentation supports each handoff
•       Ensure contingency plans and escalation processes are realistic and actionable—not just “described”

3. Strengthen Your Training Infrastructure

•       Update staff and provider MOC training materials with 2026 expectations
•       Ensure training records, remediation actions, and oversight are auditable
•       Align training content with actual operational workflows—not just policy language

4. Tighten Quality Measurement and Governance

•       Reassess MOC-specific goals and benchmarks against your actual performance data
•       Ensure leadership oversight is documented and active, not just referenced
•       Prepare evidence showing how performance results drive program changes

5. Conduct a Pre-Submission Readiness Review

•       Evaluate narratives against scoring criteria, not just regulatory language
•       Look for gaps where processes are described but not operationalized
•       Confirm consistency across the MOC, policies, training materials, and quality reports 

The Bottom Line

 The 2026 MOC standards don’t require a wholesale redesign, but they do require a harder look at whether your documentation reflects reality. The plans that score well are the ones that use the MOC as a living care coordination framework, not a static submission document.

At MHR, we see the most successful SNPs treating the MOC as a strategic tool—aligning population analytics, care management, provider engagement, and quality improvement into one cohesive, auditable story that NCQA can clearly follow.

MHR Can Help 

MHR provides expert guidance for SNPs navigating the 2026 MOC requirements. Whether you need a readiness review, targeted support on a specific standard, or help aligning documentation to NCQA’s scoring expectations, our consultants bring the depth and precision your submission requires.

•       Schedule a MOC Readiness Review with an MHR consultant
•       Access MHR’s MOC Tools and Templates to strengthen your documentation
•       Contact us at [email protected] or visit managedhealthcareresources.com

This blog was written by Susan Moore, CEO, MHSA, RN, using the 2026 MOC standards, CY2027 SNP MOC Guidelines and Model of Care Matrix Document.

© Managed Healthcare Resources, Inc.