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
FAQ Directory: Managed Behavioral Healthcare Organization Accreditation
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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.
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 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?
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?
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 2025 Information Integrity Standard Changes and Delegation Do organizations need to conduct a delegation audit(s) on the 2025 Information Integrity standards within 12 months prior to survey submission date?
Yes, organizations must conduct a delegation audit within 12 months of the survey submission date.
For example, an organization with a Renewal Survey on July 1, 2025, will be surveyed on the 2025 standards, and will be expected to audit its delegates on CR 9, Element C, factors 5–7 in HPA/MBHO (CR 3, Element C, factors 5-7 in CRPN) at least once in the prior year (between July 2024 and the July survey submission date).
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
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
8.15.2024 Retroactive Changes to System Controls Standards NCQA posted a memo with changes to the NCQA Accreditation Standards for the 2024 and 2025 Standards Years indicating that organizations are no longer required to describe their process for system controls monitoring or their auditing methodology in their policies and procedures (e.g., UM 12, Element A, factor 7 in HPA is scored NA). Does this mean organizations are no longer required to monitor their UM and CR system controls as required in the oversight elements (e.g., UM 12, Element B in HPA)?
No. Organizations are still required to monitor for system controls. The NA for the system controls policies and procedures requirement (e.g., UM 12, Element A, factor 7, in Health Plan Accreditation) does not affect an organization’s ability to meet the corresponding system controls monitoring requirement (e.g., UM 12, Element B in Health Plan Accreditation); it means the organization is not required to describe the monitoring process in its policies and procedures, but must monitor that its systems are protecting data from unauthorized modifications. Also, as noted in “Related information” in the monitoring requirements (e.g., UM 12, Element B in Health Plan Accreditation), NCQA only reviews specific components for monitoring (e.g., for UM, NCQA reviews that the organization monitored receipt and notification dates).
Note: The referenced memo is on the NCQA website at https://www.ncqa.org/wp-content/uploads/2025-Retroactive-Changes-Memo_Final.pdf. It applies to the 2024/2025 standards year only; no exceptions (NA scores or other changes) will be made for the 2023 or prior standards years. Surveys conducted on standards prior to 2024 standards will be reviewed and scored accordingly; any corrective actions issued prior to the 2024 standards still apply
MBHO 2024
5.15.2024 Use of AI for UM Decisions May organizations use artificial intelligence to make medical necessity denial decisions or appeal decisions?
No. NCQA UM standards do not allow the use of AI to make medical necessity denial decisions, or any appeal decisions.
If an organization uses AI in the UM process, medical necessity review requires that denial decisions be made only by an appropriate clinical professional and appeal decisions require same-or-similar specialist review, as specified in the NCQA standards.
MBHO 2024
3.15.2024 New Consensus-Based Entity for Performance Measurement Since the National Quality Forum (NQF) is no longer the consensus-based entity for CMS, what source can we use to identify standardized measures?
Battelle replaced NQF as the consensus-based entity for CMS; the Battelle Partnership for Quality Measurement (PQM) Submission Tool and Repository Measure Database can be found here: https://p4qm.org/. Organizations may only use measures classified as “Endorsed."
MBHO 2013