2026 SMAC Submission Requirements for Dual Eligible Special Needs Plans
Each week, we scan the latest CMS memos to find the most important ones that apply for PACE programs. Below is a summary of what you need to know.
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Introduction
The Centers for Medicare & Medicaid Services (CMS) has issued crucial guidance for Medicare Advantage Organizations (MAOs) offering Dual Eligible Special Needs Plans (D-SNPs) for the contract year 2026. Organizations are required to complete essential activities in the Health Plan Management System by July 7, 2025, including necessary attestations and document uploads. Compliance with these requirements ensures alignment with relevant federal regulations.
Key Dates and Deadlines
- Memo Date: June 5, 2025
- SMAC Submission Deadline: July 7, 2025, at 8:00 PM ET
PACE Compliance
This memo is relevant to PACE programs because it outlines essential submission requirements for Medicare Advantage Organizations (MAOs) seeking to offer a Dual Eligible Special Needs Plan (D-SNP) for the contract year 2026. Although PACE programs are not directly considered in these requirements, understanding these regulatory procedures can be beneficial for broader compliance perspectives.
MAOs must complete necessary attestations, upload State Medicaid Agency Contracts (SMAC), and corresponding Matrix Upload Documents by the designated deadline of July 7, 2025. Each SMAC must comply with 42 CFR 422.107(c) and (d) requirements.
For PACE organizations, it is crucial to understand the framework and deadlines within which MAOs operate, as similar compliance obligations may apply to different or future criteria connected to PACE.
To ensure compliance within this segmented deadline-driven environment, plans should:
– Prepare early by assembling all required documentation well ahead of the submission deadline.
– Ensure clarity in the documentation to specify contractual obligations, especially where multiple plan benefit packages are involved.
– Utilize available resources such as the HPMS paths provided for templates and guides.
By maintaining informed vigilance on such compliance schedules, PACE organizations can better anticipate regulatory expectations and minimize non-compliance risks in their own operations.
Required Actions
All Medicare Advantage Organizations (MAOs) seeking to offer a Dual Eligible Special Needs Plan (D-SNP) in Contract Year 2026 must complete the specified tasks in the Health Plan Management System (HPMS) by July 7, 2025, at 8:00 PM ET.
1. Complete necessary attestations within HPMS.
2. Upload State Medicaid Agency Contracts (SMAC) for each PBP offered.
3. Upload corresponding Matrix Upload Documents, including supporting documentation, specifying the PBP applicable for each SMAC.
FAQs
- “What are the key deadlines for submitting SMAC for D-SNPs in CY 2026?”
- “How can Medicare Advantage Organizations submit State Medicaid Agency Contracts?”
- “What documents are required for SMAC submissions for D-SNPs?”
- “Where can MAOs find instructions for SMAC submissions?”
- “Who to contact for questions regarding SMAC or HPMS?”
