health equity ncqa Nov 15, 2023
MHR Blog Post Nov 15 2023

By Nancy Ross Bell, RN

Word count:  956

Estimated time to read:  3 minutes

When delegating health equity activities to NCQA-Accredited Health Equity (HE) Organizations,  Health Plans & MBHOs must consider requirements on product line match, membership, and dates. Read below for some highlights, keeping in mind that full details are contained in the NCQA standards and Appendix 2 on Delegation & Automatic Credit.

Delegating to HE-Accredited Entities Reduces Administrative Burden

The number of organizations earning NCQA HE Accreditation is increasing and can be found on NCQA’s Report Card site for Health Plans and Other Health Care Organizations. By delegating certain elements and factors to one of these entities, health plans and MBHOs may be eligible for automatic credit and waiving of delegated oversight.

Being Accredited Helps Service Organizations Avoid Duplication

Some NCQA HE-Accredited Organizations may be ones you already contract, such as provider organizations, wellness and population health organizations, and community-based organizations. If not already accredited, they may be pursuing it to help streamline their processes and avoid duplication of effort and oversight, as they tend to provide similar functions for multiple Health Plans and MBHOs. If not pursuing NCQA HE Accreditation, Health Plans & MBHOs could consider this as a contractual requirement in the future.

What is automatic credit?

A requirement is scored “Met” if the organization delegates an eligible NCQA activity to an NCQA -Accredited…delegate. Specific criteria must be met to receive automatic credit. (Appendix 2, Definitions)

Certain Standards are Eligible for Automatic Credit

Specific requirements for the delegation of health equity are found in the 2024 HE Standards, Appendix 2 – Delegation and Automatic Credit Guidelines.

Refer to Table 3 for Health Plan standards and to Table 5 for MBHO standards for a complete description of each element and factor. Not all factors within an element or all elements within a standard are eligible for automatic credit.

Eligible Health Plan Standards

  • PHM 1 A, 6                                               
  • PHM 2 B, 5 & 6                                         
  • PHM 2 C, 3                                               
  • NET 1 A                                                     
  • NET 3 B, 1                                                 
  • NET 3 C, 1                                                 
  • NET 5 A, 8                                                 
  • ME 2 A, 5                                                  
  • ME 2 B                                                      
  • ME 7 A, 5                                                  
  • ME 7 B, 5

Eligible MBHO Standards

  • QI 3 A
  • QI 8 A, 5 & 6
  • QI 8 B, 3
  • RR 2 A, 5
  • RR 2 B, 5
  • RR 3 A, 4
  • RR 3 B, 8
  • RR 4 A, 8                                                     

Consider this scenario. You work with three external entities, including a wellness organization, a provider organization, and a community-based program for people with diabetes. All collect and assess data on race, ethnicity, and language for your Health Plan’s members. Is your Health Plan eligible for automatic credit for PHM 2 B 5 & 6 for all three entities?

In this scenario:

The wellness organization achieved NCQA HE Accreditation last year in advance of your organization’s Health Plan survey.  

  • Your organization is eligible for automatic credit for PHM 2 B, 5 & 6

          The provider organization is scheduled for its HE Accreditation survey in six months, which is after the time your organization submits its own survey.

  • Your organization is not eligible for automatic credit at its upcoming Health Plan survey but may be eligible for subsequent ones.

The community-based program has no plans for NCQA HE Accreditation.

  • Your organization is not eligible for automatic credit and must follow all standards for delegation according to the NCQA standards.

Know the Date of Your Delegates’ HE Accreditation Status

The delegate must be NCQA Accredited in HE for the function they perform on or before the date of your organization’s survey tool to be eligible for oversight relief and automatic credit.

Automatic Credit by Product Line

There must be a product line match between the products and eligibility for automatic credit.  For example, if an organization with multiple product lines only delegates a health equity activity for its Medicaid product, then automatic credit is only eligible for Medicaid.

How Does Membership and Product Line Impact Automatic Credit?

To be eligible for automatic credit, the NCQA-HE Accredited delegate must perform the delegated functions for at least 90% of the organization’s membership, with five important considerations.

  1. If the organization delegates functions that NCQA reviews separately for each product line, then the 90% threshold is calculated separately for membership in each product line.
  2. If there are two or more delegates performing a function, then the 90% threshold is cumulative for the same delegated function.
  3. If the organization has two or more product lines and manages them the same, 90% is cumulative across all product lines.
  4. If the organization has two or more product lines and manages them differently, then the 90% threshold is calculated by product line, for example, when an HE activity is delegated for Commercial but not for Medicaid or Medicare.
  5. All members for whom the organization is not responsible and are excluded or carved out from the delegated function or service are also excluded from the membership total.

How can MHR help?

When working with MHR, your consultants will help ensure you are optimally prepared for delegation to NCQA HE-Accredited organizations.  We will:  

  • guide you on optimizing the eligibility of automatic credit
  • assess your delegation and vendor agreements against standards
  • ensure that your NCQA delegation worksheet is completed accurately

Additionally, when it comes to delegation, there are other special considerations that MHR can advise, including delegating to corporate families, distinguishing vendors from delegates, and strategizing on working with external entities to reduce administrative burden.

Call to Action:    

  • Carefully read all requirements described in Appendix 2.
  • Check the HE Accreditation status of organizations in which you do business.
  • Reach out to MHR for Training on the HE Standards or Delegation.
  • Contact Susan Moore, MHR President and CEO. 

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