Collecting Data From Members or Practitioners During March 1, 2020 –June 30, 2021

Organizations might have difficulty obtaining feedback or collecting data from members or practitioners (e.g., surveys or focus groups, as required for elements such as ME 5, Element C and ME 6, Element C). If these activities were scheduled during the March 1, 2020 – June 30, 2021 time frame, NCQA will not require organizations to actively collect this data. Organizations must document that the activity was scheduled during the March 1, 2020 – June 30, 2021 time frame in their disaster management plan and the circumstances that prevented them from collecting data.

Organizations must provide 2 years of an established schedule as evidence that data collection would have occurred during the March 1, 2020 – June 30, 2021 period (the documented 2018 and 2019 schedule or the 2019 and 2020 schedule).

If complaint/appeal analysis is required: Organizations are required to collect and evaluate information regarding complaints or appeals for the elements in the table below. The table identifies applicable elements in in HP 2019 and 2020; however, guidance also applies to applicable requirements in derivative products (e.g., MBHO, UM-CR-PN).

If complaint/appeal analysis is required

HP 2020HP 2019
NET 2, Element A: Access to Primary CareNET 2, Element A
NET 2, Element B: Access to Behavioral HealthcareNET 2, Element B
NET 2, Element C: Access to Specialty CareNET 2, Element C
NET 3, Element A: Assessment of Member Experience Accessing the NetworkNET 3, Element A
ME 7, Element C: Annual Assessment of Nonbehavioral Healthcare Complaints and AppealsQI 4, Element C NET 4, Element C
ME 7, Element D: Nonbehavioral Opportunities for ImprovementQI 4, Element D NET 4, Element D
ME 7, Element E: Annual Assessment of Behavioral Healthcare and ServicesQI 4, Element C NET 4, Element C


If complaint/appeal analysis is optional:
NCQA encourages organizations to provide an analysis of complaint or appeal data in lieu of member or practitioner feedback for the requirements below. If analysis is not possible, the organization’s disaster management plan should document its actions. The table below identifies the applicable elements in HP 2019 and 2020; however, guidance also applies to applicable requirements in derivative products (e.g., MBHO, UM-CR-PN).

If complaint/appeal analysis is optional

HP 2020HP 2019
PHM 6, Element A: Measuring EffectivenessPHM 6, Element A
NET 1, Element A: Cultural Needs and PreferencesNET 1, Element A
NET 1, Element C: Practitioners Providing Specialty CareNET 1, Element C
NET 5, Element C: Assessment of Physician Directory AccuracyNET 6, Element C
NET 5, Element D: Identifying and Acting on OpportunitiesNET 6, Element D
ME 2, Element B: Interpreter ServicesRR 3, Element B
ME 3, Element C: Assessing Member UnderstandingRR 4, Element C
ME 7, Element F: Behavioral Healthcare Opportunities for ImprovementQI 4, Element F NET 4, Element D
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