FAQ Directory: Health Plan Accreditation

No. Notice of Medicare Non-Coverage (NOMNC) denial files are out of NCQA’s scope of review and should be excluded from the UM file universe.

HP 2024

Yes. Organizations may submit the mail service delegate's timeliness report of mail distribution of UM denials and appeals in lieu of an audit. This is not required to be specified in the delegation agreement.

HP 2024

Yes. NCQA uses language in the Explanation that organizations may use more general or extensive language to query practitioners about impairment.

Note: This question was previously posted on August 15, 2023 and reevaluated by NCQA. This FAQ answer replaces the previously posted response.

HP 2024

Yes. The following updates to the Exceptions section language are effective immediately and will be included in a Policy Update in November 2023.
This element is NA if:

• The organization does not delegate UM activities.
• Delegation arrangements have been in effect for less than 12 months.

Factor 1 is NA for mail service delegates.
Factors 2–6 are NA for Interim Surveys.
Factors 3 and 4 are NA if a mail service delegate distributes information for an element with an annual frequency. The delegation agreement in Element A must outline the frequency for reviewing the delegate’s reports (i.e., annual or semiannual) (UM 13, Element A, factor 4).
Factors 5 and 6 are NA if the delegate only provides cloud-based UM data storage functions and does not provide services that create, modify or use UM data.
Factors 5 and 6 are NA for mail service delegates that:

• Provide print mail service only. 
• Do not have access to the organization’s UM system. 
• Do not have a UM system of their own.
• Do not modify or store the UM data sent by the organization. 
• Return UM data provided by the organization.

All bullets must be addressed in a delegation agreement for factors 5 and 6 to be NA.
Factor 6 is NA if the organization did not identify any date modifications or if all identified date modifications met the delegation agreement or the delegate’s policies and procedures.

Note: The strikethrough text indicates changes to the Exceptions section.

HP 2024

No. An organization that only provides print services is not considered a delegate or a vendor, and is outside the scope of NCQA requirements.

HP 2024

Yes. Using UM 13: Delegation of UM as an example, the following describes factors that would be considered NA:
UM 13, Element A: Delegation Agreement

• Factor 3 (semiannual reporting): This factor is NA for mail service organization delegates that only perform annual distribution (e.g., UM 11, Element B (annual updates for pharmaceutical restrictions/preferences).
  • Note: Factor 4 (performance monitoring): Annual distribution must be specified as part of the organization’s process for monitoring delegate performance, if applicable.
  • Factor 3 is not scored NA for distribution that occurs more frequently than annually (e.g., denial and appeal notices).
• Factor 5 (process for providing member experience and clinical performance data to delegates when requested): This factor is NA for mail service organization delegates.

UM 13, Element C: Review of the UM Program:

• Factor 1 (annual review of delegate’s UM program): This factor is NA for mail service organization delegates.
• Factor 4 (semiannual evaluation of reports): This factor is NA for mail service organization delegates that only perform annual distribution.
  • Factor 4 is not scored NA for distribution that occurs more frequently than annually (e.g., denial and appeal notices).

Note: Factor 2 (annual audits): This factor is not scored NA, but the organization may submit the delegate’s timeliness report of mail distribution in lieu of an audit.  This must be specified in the delegation agreement.

Update: The strikethrough text is an update to the FAQ posted on October 15, 2022.

HP 2024

Yes, the following CAQH question meets the intent of the requirement in CR 3, Element C, factor 2:

HP 2024

NCQA requires practitioners to attest to their lack of present illegal drug use, but not to past drug use or history of drug use.

Organizations are not required to refer exclusively to the present; therefore, an organization may choose to ask about both present and past drug use.

HP 2024

No. Only addressing the UM denial notification to the provider does not meet the intent of the requirement. The UM denial notification must also be addressed to the attending/treating practitioner.

If information on the attending/treating practitioner was not provided with the request, the organization attempts to identify the practitioner and documents its efforts to identify the practitioner. If the organization is not able to obtain the name of the attending/treating practitioner, the practitioner’s name is not required. In such a case, the organization must address the notification "To the Attention of the Attending/Treating Practitioner.”

For urgent concurrent decisions, the organization may inform the hospital Utilization Review department staff without attempting to identify the attending/treating practitioner, with the understanding that staff will inform the practitioner.

In all cases, if the practitioner is not known, the organization must address the notification “To the Attention of the Attending/Treating Practitioner”; the practitioner’s name is not required.

HP 2023

Yes. Organizations may use an API to access data from a primary or approved source, and must provide documentation that the API collects information only from primary or approved sources.

Organizations that use an API must still meet the “Appropriate documentation” requirements in CR 1, Element A, including documentation that the organization's staff reviewed the information.

As noted in an FAQ from February 15, 2023, use of another entity’s software to collect credentialing information is not considered delegation unless the entity also reviews the information on the organization’s behalf.

HP 2023

Yes, if the delegation agreement addresses the required information in the Explanation (e.g., CR 8, Element A, factor 3 for credentialing). The delegation agreement must specify:

• How often the organization accesses the reports (i.e., must be at least semiannually). The frequency must be specified. Stating “on demand” or “as needed” does not meet the requirement.
• What information is reported by the delegate in the delegate's system about the delegated activities.
• How the organization will access the delegate’s system, and to whom information is reported (i.e., to appropriate committees or individuals in the organization).

HP 2023

NCQA considers the following standards to be a delegation relationship if an organization uses a mail service organization to meet the distribution requirements:

• NET 4, Element A: Notification of Termination
• NET 4, Element B: Continued Access to Practitioners
• UM 5, Elements A, B, C: Timeliness of UM Decisions
• UM 7, Elements B, C, E, F, H, I: Denial Notices
• UM 9, Elements B, D: Appropriate Handling of Appeals
• UM 11, Element B: Pharmaceutical Restrictions/Preferences
• UM 11, Element C: Pharmaceutical Patient Safety Issues

HP 2023