FAQ Directory: Long-Term Services and Supports Distinction for Health Plans

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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

HP 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.  

HP 2024

12.15.2023 Collaboration Between Medical Care and Behavioral Health Care Does collaboration between health plan staff clinicians meet the intent of the collaboration requirement in QI 4, Elements A and B?

Typically, no as health plan staff are not practicing practitioners within the health plan's network. The intent of collaboration requirements are for organizations to demonstrate collaboration between their behavioral healthcare delivery system (network practitioners) and medical care delivery system (network practitioners). 

Note: Demonstrating collaboration with an MBHO is acceptable for the collaboration with “behavioral healthcare practitioners” component of the requirement.

HP 2024

11.15.2023 Using SAM.gov for Medicare/Medicaid Sanctions Is SAM.gov an acceptable source for verifying Medicare and Medicaid sanctions?

Yes. Organizations may use SAM.gov to verify Medicare and Medicaid sanctions for CR 3, Element B, factor 2 and CR 5, Element A, factor 1.

HP 2024

11.15.2023 Notice of Medicare Non-Coverage (NOMNC) Denials For the UM file review universe, should plans include concurrent denials for Medicare members that involve issuance of a Notice of Medicare Non-Coverage (NOMNC) document?

No. Notice of Medicare Non-Coverage (NOMNC) denial files are out of NCQA’s scope of review and should be excluded from the UM file universe.

HP 2024

10.16.2023 UM 13, Element C Exceptions Is the Exceptions section language in UM 13, Element C going to be updated for mail service organizations?

Yes. The following updates to the Exceptions section language are effective immediately and will be included in a Policy Update in November 2023.
This element is NA if:

  • The organization does not delegate UM activities.
  • Delegation arrangements have been in effect for less than 12 months.

Factor 1 is NA for mail service delegates.
Factors 2–6 are NA for Interim Surveys.
Factors 3 and 4 are NA if a mail service delegate distributes information for an element with an annual frequency. The delegation agreement in Element A must outline the frequency for reviewing the delegate’s reports (i.e., annual or semiannual) (UM 13, Element A, factor 4).
Factors 5 and 6 are NA if the delegate only provides cloud-based UM data storage functions and does not provide services that create, modify or use UM data.
Factors 5 and 6 are NA for mail service delegates that:

  • Provide print mail service only. 
  • Do not have access to the organization’s UM system. 
  • Do not have a UM system of their own.
  • Do not modify or store the UM data sent by the organization. 
  • Return UM data provided by the organization.

All bullets must be addressed in a delegation agreement for factors 5 and 6 to be NA.
Factor 6 is NA if the organization did not identify any date modifications or if all identified date modifications met the delegation agreement or the delegate’s policies and procedures.

Note: The strikethrough text indicates changes to the Exceptions section.

HP 2024

10.16.2023 UM 13, Element C, factor 2 for mail service delegates Can organizations submit a mail service delegate's timeliness report of mail distribution of UM denials and appeals in lieu of an audit for UM 13, Element C, factor 2?

Yes. Organizations may submit the mail service delegate's timeliness report of mail distribution of UM denials and appeals in lieu of an audit. This is not required to be specified in the delegation agreement.

HP 2024

10.16.2023 CAQH Application: Illegal drug use question Does the CAQH application question about lack of current illegal drug use meet the intent of NCQA’s requirement in CR 3, Element C, factor 2?

Yes, the following CAQH question meets the intent of the requirement in CR 3, Element C, factor 2:

“Are you currently engaged in the illegal use of drugs?* ("Currently" means sufficiently recent to justify a reasonable belief that the use of drugs may have an ongoing impact on one's ability to practice medicine. It is not limited to the day of, or within a matter of days or weeks before the date of application, rather that it has occurred recently enough to indicate the individual is actively engaged in such conduct. "Illegal use of drugs" refers to drugs whose possession or distribution is unlawful under the Controlled Substances Act, 21 U.S.C. § 812.22. It "does not include the use of a drug taken under supervision by a licensed health care professional, or other uses authorized by the Controlled Substances Act or other provision of Federal law." The term does include, however, the unlawful use of prescription controlled substances.)"
 
CAQH provides additional information regarding what "currently" means that aligns with language in the explanation of CR 3, Element C, factor 2 that the organization may use more general or extensive language to query practitioners about impairment.

HP 2024

10.16.2023 External organizations providing print services only Does NCQA consider it delegation if an organization contracts with an external organization that provides print services only and does not provide mail services?

No. An organization that only provides print services is not considered a delegate or a vendor, and is outside the scope of NCQA requirements.

HP 2024

10.16.2023 Updated: Mail Service Organization Delegates Are any delegation oversight factors considered not applicable for organizations that use a mail service organization delegate to meet distribution requirements (per a July 15, 2021 FAQ)?

Yes. Using UM 13: Delegation of UM as an example, the following describes factors that would be considered NA:
UM 13, Element A: Delegation Agreement

  • Factor 3 (semiannual reporting): This factor is NA for mail service organization delegates that only perform annual distribution (e.g., UM 11, Element B (annual updates for pharmaceutical restrictions/preferences).
    • Note: Factor 4 (performance monitoring): Annual distribution must be specified as part of the organization’s process for monitoring delegate performance, if applicable.
    • Factor 3 is not scored NA for distribution that occurs more frequently than annually (e.g., denial and appeal notices).
  • Factor 5 (process for providing member experience and clinical performance data to delegates when requested): This factor is NA for mail service organization delegates.

UM 13, Element C: Review of the UM Program:

  • Factor 1 (annual review of delegate’s UM program): This factor is NA for mail service organization delegates.
  • Factor 4 (semiannual evaluation of reports): This factor is NA for mail service organization delegates that only perform annual distribution.
    • Factor 4 is not scored NA for distribution that occurs more frequently than annually (e.g., denial and appeal notices).

Note: Factor 2 (annual audits): This factor is not scored NA, but the organization may submit the delegate’s timeliness report of mail distribution in lieu of an audit.  This must be specified in the delegation agreement.

Update: The strikethrough text is an update to the FAQ posted on October 15, 2022.

HP 2024

10.16.2023 Credentialing application question about present illegal drug use Would the following question on a credentialing application meet the intent of CR 3, Element C, factor 2? “Are you currently using illegal drugs that could affect your ability to practice medicine?”

Yes. NCQA uses language in the Explanation that organizations may use more general or extensive language to query practitioners about impairment.

Note: This question was previously posted on August 15, 2023 and reevaluated by NCQA. This FAQ answer replaces the previously posted response.

HP 2024

8.15.2023 Lack of present illegal drug use Does NCQA require practitioners to attest to their lack of present and past illegal drug use?

NCQA requires practitioners to attest to their lack of present illegal drug use, but not to past drug use or history of drug use.

Organizations are not required to refer exclusively to the present; therefore, an organization may choose to ask about both present and past drug use.

HP 2024