FAQ Directory: Health Plan Accreditation

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10.15.2025 Notification of Appeal Decisions/Rights—Exceptions In UM 9, Element D and UMA 5, Element E, the exceptions for factor 7 reference appeal notifications before July 1, 2025. Is the date accurate, or is it an error?

The July 1, 2025, date is incorrect. For the 2026 standards and guidelines, factor 7 is scored NA for appeal notifications issued before July 1, 2026.  

This applies to the following Programs and Years:
HP 2026|UM 2026

10.15.2025 Semiannual reporting and evaluation requirements if delegates are NCQA-Accredited/Certified Are NCQA-Accredited/Certified delegates required to provide semiannual reporting to organizations, and are organizations required to evaluate semiannual reports from NCQA-Accredited/Certified delegates?

No. Effective immediately for delegation oversight standards, organizations receive automatic credit for the delegation agreement semiannual reporting requirement in Element A, and for the delegation oversight semiannual report evaluation in Element C, when an NCQA-Accredited/Certified delegate performs an NCQA-required activity.  

For example, in Health Plan Accreditation, NET 6, Element A, factor 3 and NET 6, Element C, factor 3 receive automatic credit for an NCQA-Accredited/Certified delegate. 

This applies to all products. 

Note: This updated FAQ replaces the original version published on September 15, 2025. 

This applies to the following Programs and Years:
CM-LTSS 2024|HEA 2024|HP 2025, 2026|CRPN 2025|MBHO 2025|UM-CR-PN 2025|UM 2026

10.15.2025 NCQA Policy Change: Medicaid Sanctions and Exclusions Verification Requirements For verification and ongoing monitoring of Medicaid sanctions and exclusions, does NCQA require organizations to use the State Medicaid agency and an additional source stated in the standards?

No. Effective immediately, NCQA changed its policy regarding Medicaid sanctions and exclusions. The State Medicaid agency is no longer a required source; it is now considered an optional source. 

For Medicaid sanctions, organizations may use any of the following sources: 

  • State Medicaid agency. 
  • AMA Physician Master File. 
  • Federation of State Medical Boards (FSMB). 
  • National Practitioner Data Bank (NPDB). 
  • SAM.gov. 

For Medicaid exclusions, organizations may use any of the following sources: 

  • State Medicaid agency. 
  • List of Excluded Individuals and Entities (LEIE) maintained by the Office of Inspector General (OIG). 
  • National Practitioner Data Bank (NPDB). 

Note: A related question was posted on July 15, 2025: “Obtaining Sanction and Exclusion information from the State Agency“. This FAQ replaces that post. 

This applies to the following Programs and Years:
HP 2025, 2026|CRPN 2025|MBHO 2025

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

This applies to the following Programs and Years:
CM 2020|CM-LTSS 2024|HP 2025, 2026|MBHO 2025

9.15.2025 Ongoing Monitoring—“At least monthly” Policy Update Retraction In July, NCQA issued a Policy Update replacing “at least monthly” with “at least every 30 calendar days” under the “Time frame for reviewing sanctions, exclusions, limitations and expiration information.” Does this change mean NCQA now requires organizations to conduct reviews strictly every 30 calendar days?

In response to customer feedback, we are retracting the Policy Update issued on July 28, 2025.

Organizations must review sanctions, exclusions, limitations and expiration information at least monthly (once per month), or within 30 calendar days of receiving a new alert, if subscribed to a monitoring service. For example, an organization might conduct a review on September 1, and conduct another on October 15, 2026.

This update applies to applicable products for both the 2025 and 2026 standard years. NCQA will accept processes that follow a monthly schedule or a 30-day interval. 

We appreciate your ongoing feedback and support.

Applicable Standards:
HPA: CR 5, Element A, factors 1-3.
MBHO: CR 5, Element A, factors 1-3.
CRPN: CRA 5, Element A, factor 3; CRC 12, Element C, factors 1-3.

This applies to the following Programs and Years:
HP 2025, 2026|CRPN 2025|MBHO 2025

9.15.2025 Ongoing Monitoring—Adverse Events: All Practitioners May organizations limit monitoring of adverse events to primary care practitioners and high-volume behavioral healthcare practitioners?

Under the 2025 standards and beyond, organizations must monitor adverse events for all practitioners. Limiting monitoring to primary care practitioners and high-volume behavioral healthcare practitioners is no longer acceptable.

This is a change from the 2024 standards.

Applicable Standards:
HPA: CR 5, Element A, factor 5.
MBHO: CR 5, Element A, factor 5.
CRPN: CRA 5, Element A, factor 5.

This applies to the following Programs and Years:
HP 2025, 2026|CRPN 2025|MBHO 2025

8.15.2025 UM Information Integrity Audit File Universe The denial and appeal Information Integrity audit universe specifies decisions (based on the notification date) made during the look-back period. Does the audit include data (decision notifications) from outside the look-back period?

Yes. When an organization conducts its UM Information Integrity audit, the audit universe includes data from the most recent 12 months from the timing of the audit. So, although the audit occurs within the look-back period, data reviewed may  include decision notification files from outside the formal look-back window, depending on timing. 

This applies to the following Programs and Years:
HP 2025, 2026|MBHO 2025|UM-CR-PN 2025|UM 2026

7.15.2025 Acceptable Titles for Reviewers The explanation for UM 9, Element D, factor 5 specifies that the reviewer's title is their position or role in the organization. How does the organization document this for external reviewers?

If a reviewer is external to the organization, the title/role must reflect it (e.g., “External Reviewer,” “External Independent Reviewer”). 

This applies to the following Programs and Years:
HP 2025|MBHO 2025|UM-CR-PN 2025

6.16.2025 Evidence for QI 3, Element D: Exchange Reporting What types of evidence may an organization submit to demonstrate reporting of the required measures for QI 3, Element D?

Organizations must provide an IDSS report and/or a CMS Proof Sheet as evidence of reporting the required measures for the Exchange product line in QI 3, Element D.

This applies to the following Programs and Years:
HP 2025

6.16.2025 Conducting Audit of Effectiveness Quarterly If an organization chooses to complete its audit and analysis for the Information Integrity requirements quarterly, may it also complete the audit of effectiveness quarterly?

Yes. Organizations that choose to conduct their audit and analysis for Information Integrity more frequently than annually (i.e., quarterly), may also conduct the follow-up audit of effectiveness more frequently. The audit must be within the 36 month time frame prescribed by NCQA. 

Applicable Standards: 

HP: CR 8, Element C; CR 8, Element D, factor 2. UM 12, Element D, UM 12, Element E, factor 2; UM 12, Element F, UM 12, Element G, factor 2. 

CRPN: CR 2, Element C, CR 2, Element D, factor 2. 

MBHO: CR 8, Element C; CR 8, Element D, factor 2. UM 11, Element D, UM 11, Element E, factor 2; UM 11, Element F, UM 11, Element G, factor 2. 

This applies to the following Programs and Years:
HP 2025|CRPN 2025|MBHO 2025

6.16.2025 QI 3, Element A: Applicability of Behavioral Healthcare Reported Measures How can an organization that reports measures for QI 3, Element A meet the 50% threshold if behavioral healthcare services are carved out and the organization therefore has a “No Benefit” audit designation for 6 of the 10 measures? 

In this example, the organization may demonstrate compliance with QI 3, Element A by providing evidence that it reported 50% of required measures it is capable of reporting. The organization would be required to report a valid, numeric rate for at least 50% of the required nonbehavioral health measures (i.e., 2 of the 4).

This applies to the following Programs and Years:
HP 2025

6.16.2025 Clarifying the Definition of “Threshold Languages” How does NCQA define “threshold languages” for CM-LTSS Accreditation and LTSS Distinction in Health Plan Accreditation?

NCQA defines threshold languages as all languages other than English spoken by 5% of the population or by 1,000 eligible individuals, whichever is less. 

Applicable Standards: 

HP: LTSS 1, Element D, factor 2. 

CM-LTSS: LTSS 2, Element A, factor 2. 

This applies to the following Programs and Years:
CM-LTSS 2024|HP 2025