FAQ Directory: Managed Behavioral Healthcare Organization Accreditation

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:

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:

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:

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:

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:

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:

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:

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. 

This applies to the following Programs and Years:

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. 

This applies to the following Programs and Years:

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

This applies to the following Programs and Years:

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.

This applies to the following Programs and Years:

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.

This applies to the following Programs and Years: