Clarifying NET 5J: NCQA Won't Let You Skate By on Policies Alone

ncqa Jan 27, 2026
net 5j evidence gap

Estimated read time: 4 minutes

Let's talk about network directories—specifically, the kind of evidence NCQA actually wants to see when they're reviewing NET 5J: Availability of Directories.

This is one of those standards where organizations think they're covered because they have a solid policy on the books. Then survey day rolls around, and the surveyor asks to see proof that members could actually access printed directories or get provider information for printed directories throughout the look-back period.

Cue the scrambling.

A recent Policy Clarification Support (PCS) response just reinforced what we've been telling clients for years: policies alone won't cut it - and once is not enough. NCQA wants to see that your process actually works—and that it's been working consistently, not just in the weeks before your survey.

What NET 5J Actually Requires

Under NET 5J (H in 2026), organizations must make directory information accessible through alternative media—meaning formats beyond your website. 

Specifically:

  1. Print
  2. Telephone

The intent is straightforward: not every member (or prospective member) wants to—or can—use your online provider search tool. NCQA expects you to have reliable, accessible alternatives in place.

The Question That Keeps Coming Up

Clients often ask us: "We have a policy that says we'll mail printed directories on request and our call center can provide directory information. Isn't that enough?"

Short answer: No.

According to PCS, NCQA reviews three types of evidence:

  1. Policies and procedures (your documented process)
  2. Supporting evidence (call scripts, screenshots, process documentation)
  3. Printed directory samples across the look-back period

Here's the key point: You need all three. A policy without operational proof is just words on paper.

NCQA wants to see that your process is real, repeatable, and has been functioning throughout the entire look-back period. The first is a process. The second is an outcome.

What This Looks Like in Practice

To satisfy NET 5J expectations, you need to be able to produce three distinct layers of evidence:

1. Written Policies and Procedures

Remember elementary school where you were taught the five Ws and then added an H? 

They are:

  • Who
  • What
  • When
  • Where
  • Why
  • How 

That applies to documented processes, and without that, you’re not comprehensive.

Your policy must clearly state:

  • How directories are made available in print
  • How members can request printed copies
  • How telephone support provides directory information
  • Timeframes for fulfillment (e.g., "mailed within 5 business days")

This is table stakes. But it's not sufficient on its own.

2. Operational Proof

NCQA reviewers will expect:

  • Screenshots showing how printed directory requests are processed in your system
  • Call scripts and call flow materials that guide staff on providing directory information by phone
  • Evidence that call centers can actually deliver provider and hospital information when members call
  • Logs or records showing requests were fulfilled

Think of this as the "how we do it in real life" layer. If your policy says members can call and get directory info, you need to show exactly how that works—and that it's reliable.

3. Printed Directory Samples Across the Look-Back Period

This is where organizations often fall short. You need multiple examples from across the look-back period, not just one sample from last month.

Examples could include:

  • Quarterly printed directory files – although NCQA states from a PCS question that it needs to demonstrate “ongoing availability.”
  • Mailing logs showing distribution dates
  • Archived PDFs or hardcopy samples
  • Evidence of printing schedules or inventory management

The goal is to demonstrate ongoing availability—that printed directories were accessible throughout the entire look-back period, not just when you knew a survey was coming.

How Many Examples Do You Need?

Here's where it gets a little murky—and why organizations get nervous.

PCS clarifies that NCQA does not prescribe a specific number of examples. But before you breathe a sigh of relief, here's the catch: the evidence must demonstrate that:

โœ… Availability is ongoing (not a one-time thing)
โœ… Processes are repeatable and consistent
โœ… Directories were actually made available during the look-back period

Translation: One example from the end of the look-back period won't fly. Neither will a single telephone script with no proof that it's actually being used.

You need to show a pattern of availability over time—not just that you can provide directories, but that you have been providing them consistently. 

As consultants we recommend at least:

First Surveys: Two in the six months of look-back period

Renewal Surveys: Two for Year One and Two for Year Two. (Also possible to demonstrate one at the beginning of the look-back period, one in the middle, and one in the end).

Quick Self-Assessment: Are You NET 5J Ready?

Ask yourself these diagnostic questions:

โœ… Do our written policies match what we actually do operationally?
โœ… Can we demonstrate that printed directories were available during the entire look-back period?
โœ… Do our call center scripts clearly guide staff on how to provide directory information by phone?
โœ… Do we have sufficient samples—across time—to prove ongoing availability?

If you're answering "maybe" or "I'm not sure" to any of these, you've got a NET 5J gap that needs attention before your next survey.

Common Mistakes We See

Mistake #1: "We have a policy, so we're good."
Not even close. NCQA wants to see that your policy translates into operational reality.

Mistake #2: "We can produce a printed directory if someone requests one."
Great—but can you prove you've been doing that consistently throughout the look-back period? One sample won't cut it.

Mistake #3: "Our call center can look up providers in the system."
Show us. Where's the script? Where's the process documentation? How do you train new staff on this? (And consultatively we would add, “How often do you remind staff that you need examples? Upon training, once in a blue moon, never?)

The Bottom Line

PCS confirms what we've been saying all along: NET 5J is not satisfied with policies alone. Organizations must demonstrate both the intent (policies) and the execution (operational evidence).

Maintaining samples and documentation throughout the look-back period isn't optional—it's essential for achieving full credit on NET 5J.

Need Help Getting This Right?

At MHR, we help organizations build NET 5 compliance that holds up under scrutiny—policies that match operations, documentation that proves consistency, and evidence that spans the full look-back period.

Whether it's directory audits, call center script reviews, or evidence gap assessments, we'll make sure you're ready when NCQA asks to see proof.

๐Ÿ‘‰ Contact your MHR consultant or reach out to us at [email protected] to schedule a network standards review.

๐Ÿ‘‰ Download our free tool, NET 5J Evidence Tracker

Learn more at managedhealthcareresources.com and follow us on LinkedIn for updates.

This blog reflects insights from MHR's network standards consulting practice and recent NCQA Policy Clarification Support (PCS) guidance. For questions about NET 5J or other provider directory requirements, connect with your MHR consultant or reach out to us at [email protected].


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