The Improving MA SNP Act of 2026 amends section 1859(f)(7) of the Social Security Act to permit private accrediting organizations other than the National Committee for Quality Assurance (NCQA) to approve specialized Medicare Advantage (MA) special needs plans (SNPs). It requires those accreditors to have an application approved under section 1852(e)(4)(C) and be determined appropriate by the Secretary; the change applies for 2026 and subsequent years.
This is a targeted, technical change: it does not rewrite MA SNP quality standards but expands who can perform the formal accreditation role. That shift matters for plan sponsors, accrediting bodies, and CMS because it alters the certification pathway for plans serving medically complex and vulnerable populations and imports new administrative discretion for the Secretary to accept additional accreditors.
At a Glance
What It Does
Revises the statutory language governing MA SNP accreditation so that, beginning in 2026, CMS may accept certifications from any private accrediting organization whose application is approved under section 1852(e)(4)(C) and that the Secretary deems appropriate. The bill also adjusts the statutory heading and places explicit reference to standards established by the Secretary.
Who It Affects
Medicare Advantage organizations operating SNPs, private accreditation bodies seeking to certify MA plans, and CMS (Health and Human Services) which will review and determine appropriateness under its existing authority. SNP enrollees are indirectly affected via changes in accreditation pathways that govern plan approval.
Why It Matters
It opens the accreditation market for SNPs, potentially increasing competition and alternative certification models while concentrating a new gatekeeping role in the Secretary's discretion. Compliance officers and plan sponsors must prepare for multiple accreditors and related operational differences in certification and oversight.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
Under current law, the statutory text governing specialized Medicare Advantage special needs plans refers to accreditation approval language tied to NCQA. This bill replaces that exclusivity with a broader rule: for 2026 and later years, any private accrediting organization that has an application approved under section 1852(e)(4)(C) may be used by CMS to approve MA SNPs if the Secretary determines the organization is appropriate.
The bill also makes a small textual change to emphasize that accreditations must be based on standards the Secretary establishes.
The change is procedural rather than substantive. It does not itself change the content of the quality standards that SNPs must meet; instead it changes who may certify that a plan meets those standards.
Practically, this means plan sponsors could seek accreditation from entities other than NCQA, provided those entities satisfy the statutory application route and pass CMS review for appropriateness. CMS will therefore continue to set or recognize the substantive standards but will have discretion over recognizing additional certifiers.Implementation will revolve around the interaction between the 1852(e)(4)(C) application process and the Secretary’s appropriateness determination.
Accrediting bodies that want to certify SNPs must obtain whatever approval is required under section 1852(e)(4)(C); CMS will need to develop processes to assess applications and issue determinations about appropriateness for SNP accreditation. For plan sponsors, the operational impact is that multiple accreditor processes, timelines, and documentation requirements may coexist, requiring updates to contracting, compliance reviews, and submission workflows.Because the bill ties the change to 2026 and later, CMS has a narrow window to adjust guidance and administrative procedures before the provision takes effect.
The bill leaves intact CMS’s role over substantive standards and enforcement, so the principal shift is a diversification in the pool of recognized accreditors and added administrative oversight tasks for CMS.
The Five Things You Need to Know
The bill amends section 1859(f)(7) of the Social Security Act to broaden who may approve MA specialized SNPs.
It removes exclusive statutory reference to NCQA and permits any private accrediting organization with an application approved under section 1852(e)(4)(C) to be used for SNP accreditation.
Accreditations must be 'based on standards established by the Secretary,' preserving CMS authority over substantive quality criteria.
The new authorization explicitly applies for 2026 and subsequent years, creating an effective starting point rather than an immediate retroactive change.
The Secretary retains a final gatekeeping role: CMS must determine an applying private accreditor to be 'appropriate' before that accreditor can approve SNPs.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Short title
Designates the statute's short name as the 'Improving MA SNP Act of 2026.' This is purely nominal but signals congressional intent that the changes target Medicare Advantage special needs plan accreditation beginning in 2026.
Replace 'NCQA approved' heading with 'Approved by an accrediting organization'
The bill revises the sub-section heading to remove the NCQA-specific label and use a generic reference to an accrediting organization. Headline changes are administrative but matter for interpretation and signal removal of an explicit statutory tie to a single named accreditor.
Explicitly tie approvals to Secretary-established standards
The amendment inserts language requiring that approvals be 'based on standards established by the Secretary.' This preserves CMS’s role in defining substantive accreditation standards and ensures that any accreditor’s certification must align with Secretary-defined criteria.
Authorize additional private accrediting organizations starting 2026
For 2026 and after, the statute permits CMS to accept accreditation from any private organization whose application is approved under section 1852(e)(4)(C) and that the Secretary deems appropriate. Practically, this adds a statutory pathway for accreditors beyond NCQA to be recognized for SNP certification, conditioned on an existing application/approval mechanism and a Secretary determination.
This bill is one of many.
Codify tracks hundreds of bills on Healthcare across all five countries.
Explore Healthcare in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Private accrediting organizations seeking market entry: They gain a clear statutory path to certify MA SNPs if they obtain approval under 1852(e)(4)(C) and are judged appropriate by the Secretary.
- MA plan sponsors that prefer alternative accreditor models: Plans gain flexibility to choose among accreditors, which could lower costs or provide accreditations better aligned with their operations.
- Potentially beneficiaries of SNPs through increased innovation: If alternative accreditors promote different quality-improvement approaches, plans might adopt changes that improve services for complex patient populations.
Who Bears the Cost
- CMS (HHS) administrative operations: CMS must review additional accreditor applications, make appropriateness determinations, and potentially manage multiple accreditation processes, increasing workload without an appropriation in the bill.
- NCQA (loss of exclusivity): The organization loses de facto exclusivity and may face reduced market share or competition for SNP accreditation business.
- MA plan compliance and contracting teams: Plans will need to navigate multiple accreditor standards, contract terms, and timing, increasing compliance complexity and administrative costs.
Key Issues
The Core Tension
The bill balances two legitimate objectives—expanding accreditation options to encourage competition and flexibility, versus preserving consistent, Secretary-defined quality standards for vulnerable SNP populations—and leaves unresolved how to ensure that broader accreditation choices do not create variability in the protection and care that SNP enrollees receive.
The bill broadens the pool of potential accreditors but leaves substantive standards, enforcement authority, and CMS oversight intact. That design preserves central regulatory control while introducing variability in the certification pathway.
A central implementation question is how CMS will operationalize the appropriateness determination under what is effectively a statutory referral to section 1852(e)(4)(C): will CMS require accreditors to meet identical technical criteria to NCQA, or will it permit alternative approaches that nonetheless satisfy Secretary-established standards? The statute ties accreditation to Secretary standards but does not define how equivalence will be judged, leaving potential for inconsistent interpretation across accreditors.
Another practical tension concerns administrative capacity and timing. The bill becomes operative for 2026 and later, giving only a limited runway for CMS to adapt guidance and internal processes.
If multiple accreditors are approved, CMS must ensure consistent oversight and enforcement across disparate accreditation frameworks to avoid a two-tiered system. Finally, the bill does not address funding for CMS review work or provide transitional rules for plans mid-cycle, which could create short-term operational friction for plans, accreditors, and beneficiaries.
Try it yourself.
Ask a question in plain English, or pick a topic below. Results in seconds.