FAQ Directory: Managed Behavioral Healthcare Organization Accreditation

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5.15.2022 System Control Requirements Review by Product Line If auditing is used to monitor an organization’s system controls or a delegate’s system controls, is sampling by product line required?

No. Sampling is not required by product line if the product lines are managed the same (a single system is used to manage all product lines).

MBHO 2022

3.15.2022 Inaccessibility of practitioners’ licensure information from Maryland Department of Health The Maryland Department of Health (MDH) experienced a network security incident on December 4, 2021, that made its network systems and practitioners’ licensing information inaccessible for primary source verification. The MDH reports that all disrupted licensing board systems were restored as of February 4, 2022. The MDH granted a grace period (with no expiration date) on practitioners’ licenses set to expire between November 2021 and February 2022, and issued temporary licenses to affected practitioners whose licenses will expire June 2022.

How will NCQA evaluate affected practitioners’ files?

For Maryland practitioners credentialed between December 2021 and February 2022, NCQA will not penalize organizations on inability to verify licensure due to the MDH network security incident. NCQA accepts the MDH’s grace period on licensure expirations and accepts temporary licenses issued by the MDH and will consider them current and valid. Organizations should adhere to guidance provided by MDH and document the guidance in the affected practitioners’ credentialing files.

MBHO 2022

2.15.2022 Annual Monitoring of CR System Controls Monitoring for Delegates Have the allowed methods to audit delegate files in CR 8, Element C, factor 5 changed?

No. Delegate files may be audited using one of the following methods as described in the factor explanation and noted below:

  • 5 percent or 50 of its files, whichever is less, to ensure that information is verified appropriately.
    • At a minimum, the sample includes at least 10 credentialing files and 10 recredentialing files. If fewer than 10 practitioners were credentialed or recredentialed since the last annual audit, the organization audits the universe of files rather than a sample.
  • The NCQA “8/30 methodology” available at https://www.ncqa.org/programs/health-plans/policy-accreditation-and-certification/

Either methodology is allowed, for consistency with other Delegation Oversight requirements for annual file audits.

MBHO 2022

2.15.2022 MBHO: Annual Monitoring of UM System Controls Monitoring for Delegates Have the allowed methods to audit delegate files in UM 12, Element C, factor 5 changed?

No. Delegate files may be audited using one of the following methods as described in the factor explanation and noted below:

  • 5 percent or 50 of its files, whichever is less, to ensure that information is verified appropriately.
  • The NCQA “8/30 methodology” available at https://www.ncqa.org/programs/health-plans/policy-accreditation-and-certification/

Either methodology is allowed, for consistency with other Delegation Oversight requirements for annual file audits.

MBHO 2022

2.15.2022 Annual Monitoring of UM System Controls Monitoring for Delegates Have the allowed methods to audit delegate files in UM 13, Element C, factor 5 changed?

No. Delegate files may be audited using one of the following methods as described in the factor explanation and noted below:

  • 5 percent or 50 of its files, whichever is less, to ensure that information is verified appropriately.
  • The NCQA “8/30 methodology” available at https://www.ncqa.org/programs/health-plans/policy-accreditation-and-certification/

Either methodology is allowed, for consistency with other Delegation Oversight requirements for annual file audits.

MBHO 2022

2.15.2022 Updated: MBHO Sampling for UM/CR System Controls Monitoring May organizations that use auditing as a method for monitoring system controls use sampling for UM 11 and CR1, Elements C and D?

Yes. NCQA has decided to allow sampling for organizations that use auditing as the method for monitoring in UM 11, Elements A – D and CR 1, Elements C and D. Organizations must use the “5% or 50 files” audit method: Organizations randomly select 5% or 50 files, whichever is less, from each applicable file type, to review against the requirements: 

  • Credentialing and recredentialing. (5% or 50 files total)  
    • At a minimum, the sample includes at least 10 credentialing files and 10 recredentialing files. If fewer than 10 practitioners were credentialed or recredentialed since the last annual audit, the organization audits the universe of files rather than a sample. 
  • UM denials (5% or 50 files). 
  • UM appeals (5% or 50 files). 

For each applicable file type noted above, the organization must determine the sample size of 5% or 50 files (whichever is less) based on all files in the file universe. The file universe includes all files with or without modifications. The sample that will be audited must include only files with modifications (i.e., modifications that meet and do not meet the organization’s policies and procedures). NCQA does not specify how the organization selects the sample once the sample size is determined using the entire file universe. It may select the sample of modified files from the universe or, if the organization can identify files with modifications, it may randomly select the sample that will be audited from only the modified files.
The organization’s analysis report must include the number or percentage of files that do not meet the organization’s policies and procedures.
Example for UM denials:

  • An organization’s UM denial file universe contains 800 files with and without modifications. Therefore, the minimum required sample for review is 40 files (5% of 800) which is less than 50 files. The organization must randomly select the 40 files for review from the total universe of 800 files or from only files with modifications (if the organization’s system has the capability to identify files with modifications). All 40 files must have a modification and are reviewed against the organization’s policies and procedures to identify noncompliant modifications.

Note: The underlined text is an update to the FAQ posted on January 15, 2022.

MBHO 2022

7.15.2021 Use of Mail Service Organizations for Distribution Requirements Is it considered delegation if an organization uses a mail service organization to meet distribution requirements?

NCQA considers it to be delegation if the organization uses another organization, including a mail service organization, to perform any function not listed in the “Vendor” section of Appendix 3. 
NCQA considers it to be a vendor relationship if the organization uses another organization (e.g., a mail service organization) to perform functions evaluated by the elements or element components listed in the "Vendor" section of Appendix 3.

MBHO 2021

4.15.2021 Vendor Relationship: RR 3, Element A Are all the requirements in RR 3, Element A considered a vendor relationship if the organization utilizes a mail vendor for distribution?

No. For RR 3, Element A, only the distribution component of the requirement is considered a vendor relationship. 

As stated in the explanation, these elements may not be delegated. The organization must create the written information, but may distribute it through a mail vendor.

MBHO 2021

4.15.2021 Provisional Status Triggers In what circumstances will an organization receive Provisional status?

An organization will receive Provisional status if it:  
 

  1. Has an overall standards score between 60 and 69.99, or  

  1. Does not achieve an element score of 80% in three or more must-pass elements.

MBHO 2021

12.15.2020 Corrective Action Process What is the corrective action process for organizations that do not meet a must-pass element?

A Corrective Action Plan (CAP) is required when an organization does not meet the minimum threshold for one or more must-pass elements. The CAP must be submitted to NCQA within 30 days after receipt of the final Accreditation status and must meet NCQA approval. The organization undergoes a CAP Survey that focuses on the failed must-pass elements (not at the factor level), i.e., all element factors, will be reviewed in addition to the factor(s) that failed the must-pass requirement.
NCQA schedules the CAP Survey for submission 6 months following the organization’s last full survey; the file review is 4 weeks later. The organization’s Accreditation status is noted “Under Corrective Action” status modifier noted on the report card during the corrective action period.
The fees for the CAP Survey can be found in the Pricing Exhibit on My NCQA. The look-back period is from the date of implementation of the corrective action up to the CAP Survey submission date and may be between 3 and 6 months before the CAP Survey submission.
After successful completion of the CAP Survey, the status modifier is removed from the organization’s status on the report card. The expiration date of the Accreditation status remains the same as the date specified in the decision that precipitated the CAP Survey. If a CAP Survey is unsuccessful, the Review Oversight Committee (ROC) may:

  • Extend the CAP status modifier, or
  • Reduce the organization’s status from Accredited to Provisional or from Provisional to Denied, or
  • Issue a Denied Accreditation status.

MBHO 2019

10.15.2020 Inclusion of Dental and Vision Denials and Appeals for UM File Review Should denials and appeals for dental and vision requests be included in the UM denial and appeal file review universes?

For all product lines, dental and vision requests covered under the organization's medical benefit are within the scope of medical necessity review and must be included for UM file review for denials (UM 4-7) and appeals (UM 9), as outlined in the file review instructions.
Dental and vision requests not covered under medical benefits are not within the scope of denial and appeal file review.

MBHO 2020

8.15.2020 CR 7: Organizational Providers NCQA added language to CR 7 in the 2020 Health Plan Accreditation standards to clarify that Element A applies to all organizational providers (e.g., telemedicine providers, urgent care centers). What does NCQA mean by “all organizational providers”?

NCQA added the word “all” to CR 7 in the 2020 HPA standards and guidelines because it expects organizations to have policies for assessing all providers with which they contract. However, under the 2020 standards and in previous years, NCQA only scores policies for providers listed in CR 7, Elements B and C.
Because the definition may not be sufficient to clearly identify which organizations NCQA considers “providers,” here is a list of provider types in addition to those listed in Elements B and C:

  • Telemedicine providers.
  • Urgent care centers.
  • Hospice.
  • Clinical labs.
  • Comprehensive outpatient rehabilitation facilities.
  • Outpatient physical therapy.
  • Speech pathology providers.
  • End-stage renal disease services.
  • Outpatient diabetes self-management training.
  • Portable x-ray suppliers.
  • Rural health clinics.
  • Federally qualified health centers.

MBHO 2020