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FAQ Directory: Managed Behavioral Healthcare Organization Accreditation

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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 3–6 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. 

MBHO 2025

5.15.2025 CAQH Application and Antidiscrimination Statement Has NCQA been in communication with CAQH about including the new NCQA requirements for race, ethnicity and language on its application?

Yes. NCQA has worked with CAQH to add a notice to its practitioner- and customer-facing provider credentialing applications, recognizing that discriminatory uses of race, ethnicity and language data are prohibited. CAQH is going live with the application update on 7/1/25.

The use of the CAQH application will be acceptable to meet CR 3, Element C, factor 6: Race, ethnicity and language in the 2025 Health Plan Accreditation standards and guidelines (and applicable products).

This applies to:
HPA: CR 3, Element A, factor 6
CRPN: CRA 3, Element A, factor 6, CRC 10, Elements A, factor 6
MBHO: CR 3, Element A, factor 6

MBHO 2025

5.15.2025 Credentialing Application: Race, Ethnicity and Language (REL) Are separate fields required for race, ethnicity and language? For example, is the CAQH application acceptable to meet CR 3, Element C, factor 6, as the CAQH application collects race and ethnicity under one field and language in another?

The requirement is for the application to have separate fields to enter responses for each of these three data points (race, ethnicity, and language). However, it would be acceptable to group these into one question if the application prompts the user to provide separate responses for race, ethnicity and language. 

Responses provided through the CAQH online portal for credentialing data application are acceptable. Although the online portal supporting the credentialing application groups the responses for race and ethnicity into one field, the practitioner is prompted to provide separate responses within the system. When a practitioner chooses his/her race, the practitioner is then prompted to provide his/her ethnicity information. Language is captured via a separate field.  

This applies to:
HPA: CR 3, Element A, factor 6
CRPN: CRA 3, Element A, factor 6, CRC 10, Elements A, factor 6
MBHO: CR 3, Element A, factor 6

Note:  A related question was posted on 3/17/2025: “Credentialing Application: Race, Ethnicity and Language (REL).” This FAQ is an update to that post. 

MBHO 2025

4.15.2025 Using software to make medical necessity approval decisions May organizations use software to make medical necessity approval decisions?

Yes, if the software uses the organization’s clinical criteria, policies and procedures and benefit package information, and the organization maintains control over the software implementation. Organizations may not use the software to make any denial decisions; those must be made by an appropriate clinical professional. Appeal decisions require same-or-similar specialist review, as specified in the NCQA standards.

NCQA considers the use of external software to make approval decisions to be a vendor relationship for applicable requirements (e.g., UM 4, Element F). Refer to Appendix 3: Delegation and Automatic Credit Guidelines for additional information.

MBHO 2025

3.17.2025 Delegation of Information Integrity Training If an organization delegates the UM and CR information integrity training requirement, must the delegation agreement be updated if it was in place before July 1, 2025, and addresses the system controls requirements under the 2022–2024 standards?

Yes. The training requirement is new and was not included in the systems controls requirement. The organization must update its delegation agreement to include delegation of UM and CR information integrity training.

The organization may add an addendum to include delegation of the new training requirement. The addendum must be mutually agreed on by the organization and the delegate.

MBHO 2025

3.17.2025 Delegation Oversight Information Integrity Annual Audit Are organizations required to conduct an annual delegation oversight audit to meet 2025 UM and CR information integrity audit requirements?

No. For standards year 2025 only, NCQA will allow all organizations, regardless of their audit schedule, to submit a detailed implementation plan in lieu of conducting the delegation oversight information integrity audit.    

The implementation plan for each applicable delegate must include:

  • The delegate’s name.
  • The entity conducting the audit (organization or delegate).
    • If the delegate conducts the audit, the implementation plan must include the organization’s plan for review and evaluation of audit findings.
  • The title of staff who conduct the audit.
  • The audit methodology.
  • The audit due date.

Organizations must submit either an information integrity audit report or an audit implementation plan (for selected delegates) at the time of survey submission for the following products:

  • HP: UM 13, Element C, factors 5-7; CR 9, Element C, factors 5-7.
  • CRPN: CR 3, Element C, factors 5-7.
  • UMCRPN: UM 13, Element C, factors 5-7.
  • MBHO: UM 12, Element C, factors 5-7; CR 9, Element C, factors 5-7. 

Organization-level information integrity audits must be conducted, and an implementation plan is not acceptable for the following requirements: 

  • HP: UM 12, Element D; UM 12, Element F, CR 8, Element C.  
  • CRPN: CR 2, Element C.
  • UMCRPN: UM 12, Element D; UM 12, Element F.
  • MBHO: UM 11, Element D; UM 11, Element F; CR 8, Element C.

Note: A related question was posted on 1/15/2025: “Do organizations need to conduct a delegation audit(s) on the 2025 Information Integrity standards within 12 months prior to survey submission date?” This FAQ replaces that post.

MBHO 2025

2.18.2025 Medicaid Sanction Look-back Period The 2025 credentialing standards for Ongoing Monitoring and Interventions (e.g., CR 5, Element A, factor 1 in 2025 HPA) require organizations to obtain sanction information from both the state Medicaid agency and one of the additional listed sources. Will the look-back period be adjusted?

No. NCQA will not adjust the look-back period. For verifications conducted before July 1, 2025, the organization or its delegate(s) can obtain information from any source in the factor requirement. Verifications conducted on or after July 1, 2025, must include the state Medicaid agency and one of the other listed sources.

This applies to:
CRPN: CRA 4, Element B, factor 2; CRC 12, Element B, factor 1.
MBHO: CR 5, Element A, factor 1.

MBHO 2025

2.18.2025 Practitioner credentialing application look-back period for the new practitioner race, ethnicity and language requirement Does NCQA expect organizations to include factor 6 in the application prior to July 1, 2025?

Applications processed before July 1, 2025, will not be held to the factor 6 requirement and will be scored NA.

Applications processed on or after July 1, 2025, will be scored on the factor 6 requirement, but will not be held against the 6-month look-back period until surveys on or after January 1, 2026.

Note: CAQH is updating its credentialing application to include fields for race, ethnicity and language, and a statement regarding anti-discrimination. Updates are scheduled to go live on July 1, 2025.

This applies to:
HPA: CR 3, Element C, factor 6.
CRPN: CRA 3, Element A, factor 6; CRC 10, Element A, factor 6; CRC 11, Element A, factor 6.
MBHO: CR 3, Element C, factor 6.

MBHO 2025

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?

No. NCQA does not require names or signatures of the reviewers on UM denial and appeal notifications. Please refer to UM 4, Element C and UM 9, Element D for documentation requirements. 

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?

For Health Plan, MBHO and Credentialing Accreditation, “processed” refers to the credentialing decision date. 

For Credentialing Certification, “processed” refers to the date when credentialing verifications are reported to the client. 

 

MBHO 2025

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.

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

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