Estimated read time: 4 minutes

Let's be honest—practitioner terminations happen. Networks shift, contracts end, and providers move on. For most health plans, it's just part of managing your network. But here's where organizations consistently trip up: assuming the practitioner can handle member notifications when they leave.

Spoiler alert: They can't. And NCQA is crystal clear about this.

What NCQA Actually Requires

Under NET 4, Element B: Continued Access to Practitioners, when a practitioner's contract ends, you must allow affected members to keep seeing that practitioner under specific circumstances:

1. Active Treatment
   Members currently being treated for a chronic or acute condition get to continue through their active treatment period—or up to 90 days, whichever comes first.
2. Pregnancy
   Members in their second or third trimester can continue care all the way through the postpartum period.

The intent? Protect members from care disruptions during critical treatment windows. Makes sense, right?

The Question That Keeps Coming Up

We’ve heard this question a lot over the years: "Our contract says the practitioner has to notify members about continuation of care. Doesn't that cover NET 4B?"

Short answer: No.

Longer answer: Absolutely not—and NCQA's Policy Clarification Support (PCS) reinforces it.

Here's what PCS made abundantly clear: NET 4B requires the organization (or its delegate) to notify members about continuation-of-care rights. Period. You cannot shift that responsibility to the terminating practitioner—even if your provider agreement says they're supposed to do it.

This is one of those "gotcha" moments where well-intentioned contract language creates a false sense of security. Just because your termination provisions mention continuity of care doesn't mean you've met the standard.

Why This Matters for Your Accreditation

If your workflow assumes the practitioner is handling notifications, you've got a NET 4B vulnerability sitting there waiting to surface during file review.

NCQA surveyors will look for:

•  Member notification letters issued by the organization or delegate
•  Documentation showing how you identified affected members
•  Evidence that continuation approvals were tracked and managed

They won't accept "the practitioner was supposed to handle it" as an answer.

What You Need to Do Right Now

1. Take Control of Member Notifications

Your termination process must include an organization-issued notice to all affected members. No shortcuts. No assumptions that the practitioner will take care of it.

The notice needs to:

•  Clearly explain continuation-of-care rights
•  State the applicable timeframes (90 days for active treatment; through postpartum for pregnancy)
•  Come from you or your delegate, not the departing practitioner

2. Document Your Policies Explicitly

Your NET 4 policy should state, in no uncertain terms:

•  The organization or its delegate is responsible for member notification
•  Notifications include continuation-of-care rights and timelines
•  Compliance with 90-day and postpartum continuation requirements

Don't leave room for interpretation. NCQA reviewers expect this language to be explicit and operational.

3. Fix Your Delegation Agreements (If Applicable)

If you delegate any part of network management or member notifications, your delegation agreements must specify that the delegate—not the practitioner—handles compliant notices.

This is a common gap. Many agreements are silent on who sends what, leaving room for confusion when terminations occur.

4. Audit Your Files Before NCQA Does

Pull a sample of recent terminations and ask:

•  Do we have compliant member notices on file for each one?
•  Can we show how we identified affected members (active treatment, pregnancy)?
•  Do we have logs or tracking that prove we issued these notices consistently?

If you're missing any of these pieces, you've got work to do before your next survey.

Quick Self-Assessment: Are You NET 4B Ready?

Ask yourself these diagnostic questions:

✅ Do our workflows explicitly assign responsibility for member notification to the organization or delegate?
✅ Do our standard termination letters include clear continuation-of-care language?
✅ Can we demonstrate consistent issuance of compliant notices throughout the look-back period?
✅ Are we tracking active treatment and pregnancy situations appropriately?

If you answered "not consistently" to any of these, you have a NET 4B vulnerability that needs attention—now, not three weeks before your survey.

The Bottom Line

Continuity-of-care protections exist to safeguard members during transitions of practitioners. NCQA expects you to own that process from start to finish—notification, tracking, approval, and follow-through.

You can't outsource it to the departing practitioner, even if your contract says they're supposed to help. The responsibility is yours.

Need Help Getting This Right?

At MHR, we help organizations tighten up network standards workflows before they become survey findings. Whether it's policy language, delegation agreement updates, or file review prep, we'll make sure your NET 4B process holds up under scrutiny.

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

👉 Click HERE to Get our free tool, NET 4B Readiness Checklist

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 4B or other network adequacy requirements, connect with your MHR consultant or reach out to us at [email protected].