Many Medicare Advantage (MA) Special Needs Plans (SNPs) breathed a sigh of relief when CMS proposed sunsetting the SNP Care Management Star measure starting in Star Year 2029 (Measure Year 2027). Just one more year of tracking timely initial and annual Health Risk Assessments (HRAs).
But hold on.
Even if the Star measure goes away, SNP audits and regulatory requirements do not. HRAs remain the foundation of SNP care management, quality oversight, and audit compliance.
Back in September, Lilac’s partner site The Healthcare Labyrinth published detailed blogs on explosive SNP enrollment growth and tightening audit trends (The Meteoric Growth of SNP Plans (SNPs) and Special Need Plans Audits Complex and Growing). Those dynamics make HRAs more important even with the removal of the aforementioned Star measure.
A quick SNP history lesson
Not long ago, SNPs were nearly phased out. CMS viewed them as marketing vehicles rather than clinically robust programs, kept alive only by temporary congressional extensions. But CMS eventually recognized their potential, especially for dual eligibles, who account for roughly 80% of SNP enrollment through D-SNPs and drive disproportionately high costs and poor outcomes.
CMS pivoted. SNPs were permanently reauthorized, and a much stricter clinical and audit framework followed. Partnering with NCQA, CMS raised expectations for Models of Care (MOCs) and dramatically strengthened audit protocols.
Early audits focused on process: Were HRAs completed? Were care plans issued?
Today’s audits go much deeper. They go beyond “box ticking” exercises and evaluate clinical delivery, care coordination, outcomes, and documentation.
Chronic Special Needs Plans (C-SNPs) and Institutional Special Needs Plans (I-SNPs) also include many dual-eligible members, with most non–D-SNP enrollment now in C-SNPs. Plans have invested aggressively in C-SNP growth for 2025–2026, prompting CMS to propose reforms that would align C-SNP requirements more closely with D-SNPs. As CMS signaled in its 2027 MA and Part D RFI, new Medicaid contracting and oversight requirements may be coming. In short, CMS is wary of repeating past “growth-first” SNP mistakes.
Why HRAs still deeply matter
HRAs remain the linchpin of SNP compliance and care delivery. As enrollment surges, many plans struggle to complete both:
1) Initial HRAs (required to be conducted within 90 days of a member’s enrollment)
2) Annual reassessments (required at least every 365 days thereafter)
Poor HRA performance can sink an audit but the real damage is downstream:
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Individualized Care Plans (ICPs) may not be effective or issued timely enough
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Preventive care plans for unreachable members may be missing
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Interdisciplinary Care Teams (ICTs) may be incomplete or misaligned
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Goals, interventions, and progress may be inadequately documented
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Interim assessments during care transitions or risk changes may not occur
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Member self-management and engagement may be limited
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Care may not be coordinated across the broader clinical enterprise
Without HRAs, plans lack the clinical backbone to manage, measure, and improve outcomes.
The operational reality and the way forward
HRAs are table stakes, but executing them at scale is increasingly difficult. Reaching a member may require up to ten outreach attempts across days and times. Multiply that by rapidly growing SNP enrollment, and the administrative burden becomes enormous.
This is where technology, and particularly agentic AI, can make a meaningful difference.
Used thoughtfully, agentic AI can:
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Conduct outreach and complete all or portions of HRAs
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Reduce administrative load on clinical teams
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Streamline information gathering and data flows for care plans, ICT activities, and goal tracking
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Detect changing risks and trigger interim assessments
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Serve as a bridge between SNP care teams and the broader clinical enterprise
With nurse care managers scarce, overloaded, and increasingly expensive, plans must rethink how work gets done. The requirements are evolving, enrollment is accelerating, and expectations are rising.
HRAs may be losing their Star measure label but they remain mission critical. Plans that invest now in scalable, tech-enabled approaches will be far better positioned to meet both clinical and compliance demands in the years ahead.
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Lilac has built a suite of agentic AI solutions enabling cost-effective, high quality member engagement. We have a module dedicated to supporting a health plan’s HRA program. Learn more at our Agentic AI Solutions page or reach out here to start a conversation about how we might be able to help you and your plan.