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FAQ Directory: Managed Behavioral Healthcare Organization Accreditation

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3.17.2025 Delegation of Information Integrity Training If an organization delegates the UM and CR information integrity training requirement, must the delegation agreement be updated if it was in place before July 1, 2025, and addresses the system controls requirements under the 2022–2024 standards?

Yes. The training requirement is new and was not included in the systems controls requirement. The organization must update its delegation agreement to include delegation of UM and CR information integrity training.

The organization may add an addendum to include delegation of the new training requirement. The addendum must be mutually agreed on by the organization and the delegate.

MBHO 2025

3.17.2025 Delegation Oversight Information Integrity Annual Audit Are organizations required to conduct an annual delegation oversight audit to meet 2025 UM and CR information integrity audit requirements?

No. For standards year 2025 only, NCQA will allow all organizations, regardless of their audit schedule, to submit a detailed implementation plan in lieu of conducting the delegation oversight information integrity audit.    

The implementation plan for each applicable delegate must include:

  • The delegate’s name.
  • The entity conducting the audit (organization or delegate).
    • If the delegate conducts the audit, the implementation plan must include the organization’s plan for review and evaluation of audit findings.
  • The title of staff who conduct the audit.
  • The audit methodology.
  • The audit due date.

Organizations must submit either an information integrity audit report or an audit implementation plan (for selected delegates) at the time of survey submission for the following products:

  • HP: UM 13, Element C, factors 5-7; CR 9, Element C, factors 5-7.
  • CRPN: CR 3, Element C, factors 5-7.
  • UMCRPN: UM 13, Element C, factors 5-7.
  • MBHO: UM 12, Element C, factors 5-7; CR 9, Element C, factors 5-7. 

Organization-level information integrity audits must be conducted, and an implementation plan is not acceptable for the following requirements: 

  • HP: UM 12, Element D; UM 12, Element F, CR 8, Element C.  
  • CRPN: CR 2, Element C.
  • UMCRPN: UM 12, Element D; UM 12, Element F.
  • MBHO: UM 11, Element D; UM 11, Element F; CR 8, Element C.

Note: A related question was posted on 1/15/2025: “Do organizations need to conduct a delegation audit(s) on the 2025 Information Integrity standards within 12 months prior to survey submission date?” This FAQ replaces that post.

MBHO 2025

3.17.2025 Credentialing Application: Race, Ethnicity and Language (REL) Are separate fields required for race, ethnicity and language?

The requirement is for the application to have separate fields to enter responses for each of these three data points (race, ethnicity, and language). However, it would be acceptable to group these into one question if the application prompts the user to provide separate responses for race, ethnicity, and language.  

MBHO 2025

2.18.2025 Practitioner credentialing application look-back period for the new practitioner race, ethnicity and language requirement Does NCQA expect organizations to include factor 6 in the application prior to July 1, 2025?

Applications processed before July 1, 2025, will not be held to the factor 6 requirement and will be scored NA.

Applications processed on or after July 1, 2025, will be scored on the factor 6 requirement, but will not be held against the 6-month look-back period until surveys on or after January 1, 2026.

Note: CAQH is updating its credentialing application to include fields for race, ethnicity and language, and a statement regarding anti-discrimination. Updates are scheduled to go live on July 1, 2025.

This applies to:
HPA: CR 3, Element C, factor 6.
CRPN: CRA 3, Element A, factor 6; CRC 10, Element A, factor 6; CRC 11, Element A, factor 6.
MBHO: CR 3, Element C, factor 6.

MBHO 2025

2.18.2025 Medicaid Sanction Look-back Period The 2025 credentialing standards for Ongoing Monitoring and Interventions (e.g., CR 5, Element A, factor 1 in 2025 HPA) require organizations to obtain sanction information from both the state Medicaid agency and one of the additional listed sources. Will the look-back period be adjusted?

No. NCQA will not adjust the look-back period. For verifications conducted before July 1, 2025, the organization or its delegate(s) can obtain information from any source in the factor requirement. Verifications conducted on or after July 1, 2025, must include the state Medicaid agency and one of the other listed sources.

This applies to:
CRPN: CRA 4, Element B, factor 2; CRC 12, Element B, factor 1.
MBHO: CR 5, Element A, factor 1.

MBHO 2025

1.15.2025 Reviewer Names on Denial and Appeal Notifications (MBHO & UM) Does NCQA require names or signatures of the reviewers on UM denial and appeal notifications?

No. NCQA does not require names or signatures of the reviewers on UM denial and appeal notifications. Please refer to UM 4, Element C and UM 9, Element D for documentation requirements. 

MBHO 2025

1.15.2025 2025 Credentialing Standard Changes and Delegation When are organizations required to hold delegates to NCQA’s 2025 credentialing standards? 

Non-file Review Annual Evaluation  

If a survey submission date is on or after July 1, 2025, the organization is assessed against the 2025 Standards and Guidelines, and is expected to hold delegate(s) to 2025 requirements.  

 

File Review Annual Audit 

If a credentialing file audit (CR 9, Element C, factor 2 in HPA/MBHO; CR 3, Element C, factor 2 in CRPN) is scheduled to occur before July 1, 2025, the organization should continue the routine scheduled annual delegation audits for credentialing and recredentialing files, and audit the files against the 2024 credentialing verification time limits.  

If a credentialing file audit is scheduled to occur on or after July 1, 2025, credentialing files processed by the organization’s delegate(s) before July 1, 2025, are assessed against 2024 verification time limits; files processed by the organization’s delegate(s) on or after July 1, 2025, are assessed against 2025 verification time limits.

MBHO 2025

1.15.2025 CR Information Integrity - Auditing of non-file review credentialing information for inappropriate documentation and updates Do organizations need to audit credentialing meeting minutes and ongoing monitoring reports for all practitioners randomly selected from the file audit universe during the annual credentialing information integrity audit?

Yes. During the audit in CR 8, Element C in HPA/MBHO (CR 2, Element C in CRPN), organizations must review all credentialing information in Element A associated with the selected practitioners’ files. This includes all credentialing verification information, credentialing committee minutes and ongoing monitoring reports.

MBHO 2025

1.15.2025 NPDB: Acceptable Source for Medicare and Medicaid Exclusions (MBHO) Is the NPDB an acceptable source for Medicare and Medicaid exclusions?

Yes. The NPDB is an acceptable source for both Medicare and Medicaid exclusions.  

For Medicaid, organizations must obtain exclusion information from the state Medicaid agency, in addition to either of the following sources: 

  • NPDB, or 

  • List of Excluded Individuals and Entities maintained by OIG and available over the internet). 

For Medicare, organizations may obtain exclusion information from any of the NCQA acceptable sources. 

MBHO 2025

1.15.2025 Sources for Medicare Sanctions (MBHO) Are organizations required to verify Medicare sanctions from all of the following sources?
• AMA Physician Master File.
• FSMB.
• NPDB.
• SAM.gov.

No. The requirement is that organizations verify Medicare sanctions from any of those sources, but there is no requirement to verify sanctions from all of them. 

MBHO 2025

1.15.2025 Define “processed” related to credentialing files Under the verification time limits, NCQA added a note that states the new verification time limits apply to files processed by the organization or its delegate(s) on or after July 1, 2025. Files processed before July 1, 2025, are scored against the previous verification time limits. What does “processed” mean for Health Plan and Credentialing Accreditation and Credentialing Certification?

For Health Plan, MBHO and Credentialing Accreditation, “processed” refers to the credentialing decision date. 

For Credentialing Certification, “processed” refers to the date when credentialing verifications are reported to the client. 

 

MBHO 2025

10.15.2024 Hurricanes and other Natural Disasters Does NCQA make accommodations for organizations that have been impacted by a natural disaster and experienced a disruption in operations?

NCQA makes disaster accommodations on a case-by-case basis during the accreditation survey process.

The organization must document the events from the disaster that prohibited your organization from meeting the standard/element. During the accreditation survey, the surveyor will document all findings which will be reviewed by our Review Oversight Committee (ROC) to determine if any accommodations or exceptions should be granted.

The organization should communicate with the assigned ASC if accommodations are requested.

MBHO 2025