FAQ Directory: Case Management

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9.15.2025 Semiannual reporting and evaluation requirements if delegates are NCQA-Accredited and Certified Are NCQA-Accredited or Certified delegates required to provide semiannual reporting to organizations and are organizations required to evaluate semiannual reports from NCQA-Accredited or Certified delegates?

No. Effective immediately, organizations receive automatic credit for the delegation agreement semiannual reporting requirement and delegation oversight semiannual report evaluation requirements in Elements A and C, when an NCQA-Accredited or Certified delegate performs an NCQA-required activity. For example, UM 12, Element A, factor 3 and UM 12, Element C, factor 4 do not apply to a delegate that is NCQA-Accredited or Certified.

If a delegate is no longer NCQA-Accredited or Certified, the organization must immediately begin evaluating semiannual performance reports from the delegate.

CM 2026

9.15.2025 Prioritizing Case Management Goals Updated Can multiple case management goals be assigned the same priority level; for example, “high”?

Yes, multiple goals can be assigned the same priority level (e.g., “high”), but the organization must still clarify the relative importance of each goal within the same assigned level. The intent of prioritization is to show how goals compare to one another in terms of urgency or importance.

For example, if three goals are all marked “high,” the organization must indicate which of those is the highest priority, second highest, and so on.

Update Notice:
This FAQ is being updated to clarify implementation expectations.
Organizations will have 90 days to implement the guidance outlined in this FAQ.
This means that organizations must adhere to the updated FAQ for surveys conducted on or after January 1, 2026.
Prior to January 1, 2026, organizations may continue to prioritize goals and reporting frequencies as they have in the past.

Applicable Standards:

HPA: PHM 5, Element E
MBHO: QI 8, Element I
CM: CM 4, Element B
CM-LTSS: LTSS 3, Element C

CM 2026

7.15.2025 Licensure Compact Arrangements Does NCQA require clinicians to be licensed in every state where they provide services to patients?

Yes. Applicable clinical staff must be licensed and verified in all states where they provide care to members. 

A licensure compact arrangement between states is acceptable if the clinician’s licensure was primary source verified in the clinician’s home state. NCQA reviews the compact agreement for evidence that the state (or states) accepts the home state’s license in lieu of state licensure. 

CM 2020

1.15.2025 Verification of Licensure Does a clinician who is licensed to practice in multiple states need to be verified in each state?

For CM 7, Element E, organizations must verify the license of clinical staff only in states where they provide services to patients.

CM 2020

6.15.2023 Use of a Delegate's Self-Service Portal for Delegation Reporting Is it acceptable for organizations to pull reports from a delegate’s system for the delegation agreement reporting requirement?

Yes, if the delegation agreement addresses the required information in the Explanation. 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).

CM 2023

5.15.2023 Definition of Annual Does NCQA’s definition of “annual” allow for a 2-month grace period?

As noted in the Glossary appendix, NCQA’s long-standing definition of “annual” is 12 months plus a 2-month grace period (12–14 months). “Grace period” refers to allowing organizations to complete an activity after it is due and not before it is due.

CM 2023

2.15.2023 Use of software to collect credentialing information Is it considered delegation if an organization uses software to only collect credentialing information?

No. The use of another entity’s software to collect credentialing information is not considered delegation unless the other entity also reviews the information on the organization's behalf. NCQA standards allow organizations to use software to collect credentialing information from approved sources, as long as organization staff document that the information was reviewed and verified.

CM 2023

2.15.2023 CM: Use of software for evidence-based clinical guidelines for CM 4, Element A For CM 4, Element A, factor 1, is it considered delegation if an organization uses evidenced-based clinical content licensed for use in their own case management system?

No. The use of another entity’s evidence-based content within the organization’s case management system is not considered delegation if the organization maintains control over how the content is used and can customize it as needed. The evidence used to support the content must be cited.

CM 2020

12.15.2019 Excluding organization employees and their dependents from complex case management (CCM) file review Should organizations exclude employees and their dependents from the CCM file review universe?

Yes. Employees and their dependents are excluded from the CCM file review universe.

CM 2019

10.15.2019 PHM 5: Assessment and Evaluation Does a combined summary of all factors in the assessment meet the requirement for documenting the conclusion of the initial assessment for PHM 5, Elements D and E?

Yes. Assessment and evaluation each require a case manager or a qualified individual to draw and document a conclusion about the data or information collected. Raw data or answers to questions do not meet the requirement; there must be a documented summary of the meaning or implications to the member’s situation, so data can be used in the case management plan.
The organization must draw a conclusion for each factor (unless otherwise stated in the explanation). This may be in separate summaries for each factor or in a combined summary, or in a combination of these.

CM 2019

3.15.2019 LTSS 4, Element C: Analysis of Unplanned transitions The explanation for LTSS 4, Element C, factor 1 states that analysis includes patterns of unplanned admissions, readmissions, emergency room visits and repeat visits, and admission to participating and nonparticipating facilities.
Is the organization required to include all these areas to meet the intent of the factor?

No. The organization is not required to include all these areas in its analysis, but at a minimum, must evaluate rates of unplanned admissions to facilities and emergency room visits to identify areas for improvement.

CM 2019

9.15.2018 Life-planning activities for Complex Case Management (CCM) Policies and Assessment Are organizations required to address life-planning activities at the first contact and start of the CCM initial assessment?

No. After consideration, NCQA removed the requirement for case managers to address life-planning activities at the start of the initial assessment (first contact). This FAQ replaces the previous FAQ issued on October 15, 2017 (which has been deleted) regarding first contact, and the workbook has been adjusted to accommodate the change.

CM 2019