If an organization cannot meet NCQA requirements because of changes in operations due to COVID-19, it must document modifications made for all applicable standards and file review elements. This will provide NCQA with relevant details and prevent organizations from being penalized for their emergency response efforts. For example, if the organization delays annual QI work plan activities, suspends nonessential written communications to members and performs expedited credentialing of practitioners who are part of emergency response efforts, its disaster management plan should detail these activities and the original and delayed dates within each applicable element.
In addition to the disaster management plan, your organization must complete a COVID-19 Impact Tracker, detailing the impact of COVID-19 to applicable elements, and your mitigation efforts. The tracker is housed in IRT, in a new COVID-19 link in the Organization Background section. Both the tracker and required disaster management plan must be uploaded to IRT and included with your survey submission.
Disaster management plans should also document any policy, procedure or process changes for functions addressed by the standards that occur during the March 1, 2020 – June 30, 2022 time frame. For example, if UM prior authorization requirements were waived, this should be documented.
For credentialing, the documented disaster management plan must identify providers not previously in the network and outline the guidelines allowing these practitioners to provide care for members that was implemented from March 1, 2020 – June 30, 2022.
Disaster management plans must be submitted with the organization’s survey tool for each accreditable entity. If the accreditable entity uses its parent company’s disaster plan (as written, or as adopted or modified), it may provide the plan as its own.
NCQA does not require that disaster management plans pre-date the COVID-19 emergency. The organization may be following a pandemic response plan that was in place prior to COVID-19 or may have created a plan as a result of COVID-19.