Practitioner Networks, Disparity Measurement, and What Health Plans Must Do Even If They Don't Own a Clinic

HO 5's expanded network standard — plus the NCQA policy clarification every managed care organization needs to read.

Effective for NCQA surveys on or after July 1, 2026

In Blog 1, we covered the structural overhaul of Health Outcomes Accreditation — the new name, the retirement of gender identity collection, the expansion of HO 2 data requirements, and the entirely new disability accommodations standard (HO 4). In this post, we go deeper into practitioner and care site network requirements in HO 5, cover disparity measurement changes in HO 7, and walk through what NCQA has clarified in policy guidance about health plans that contract with — rather than own or operate — clinical facilities.

If your organization is a managed care plan that does not own a clinic but contracts with a broad network of providers to serve your members, pay close attention to Section 2. This clarification affects virtually every MCO pursuing Health Outcomes Accreditation.

1.  HO 5: From Two Elements to Five

The former HE 4 (Practitioner Network Cultural Responsiveness) had two elements. HO 5 — now called Practitioner Network and Care Site Responsiveness — has five. The expansion reflects the program's new disability-inclusive scope and the formal separation of what was previously a single large element into distinct, separately scored requirements.

The restructuring of the former HE 4, Element A is the most important change to understand:

• Former HE 4, Element A, factors 1–3 (data collection on practitioner languages, language services at practices, and practitioner race/ethnicity) → now HO 5, Element A: Practitioner and Site-Level Information.
• Former HE 4, Element A, factors 4–6 (publishing practitioner language and race/ethnicity information in directories) → now HO 5, Element B: Availability of Information on Practitioners and Care Sites. This is a new standalone element.

Two completely new elements address care site physical accessibility — directly tied to the new HO 4 disability accommodations standard:

• HO 5, Element D: Information on Accessible Equipment — organizations must collect and share information about accessible equipment available at contracted care sites.
• HO 5, Element E: Enhancing Care Site Accessibility — organizations must have processes for improving physical and programmatic accessibility at care sites.

HO 5, Element C (Enhancing Network Responsiveness, formerly HE 4, Element B) carries over with revised factor language, updated data sources and scope of review, and a new exception for non-health plans. We see HO 5 as one that significantly increases the resource needs for staff to gather and use data. For Elements A, B, and D, you can obtain a Partially Met score by meeting one factor and for Elements C and E you need at least two factors to meet Partially Met.

2.  The Policy Clarification Every Health Plan Must Know

NCQA received questions about whether HO 5, Elements A and B apply to health plans that do not own or operate clinical facilities. The answers have significant implications for managed care organizations.

Simply contracting with external providers does not exempt a health plan from the care site accessibility and disability accommodation requirements in HO 5. NCQA has confirmed this in policy clarification guidance.

NCQA POLICY CLARIFICATION

"In-person clinical or behavioral health care sites" refers to physical locations where patients receive face-to-face medical or behavioral health services. If a health plan does not own or operate those facilities but contracts with practitioners or care sites where members receive face-to-face services, HO 5, Elements A and B, factors 3–4 are still applicable to that health plan. 

In plain terms: if your members receive in-person care through your contracted network — and virtually all MCO members do — these factors apply to your organization. You are responsible for collecting information on care site accessibility and disability accommodations at your contracted sites, even if you do not own or operate those sites.

A follow-up question raised an additional layer of complexity. The explanation for HO 5, Elements A and B, factor 4 references using the same response options from HO 2, Element E — an element specific to care delivery organizations (CDOs). This led to the question of whether health plans that are not CDOs might have an exception from factor 4.

NCQA POLICY CLARIFICATION — February 20, 2026

For HO 5, Elements A and B, Factor 4, an exception is NOT available for organizations that are not care delivery organizations. NCQA acknowledges the explanation referencing HO 2, Element E may cause confusion and NCQA will update the language in a future publication. The requirement itself stands. 

The bottom line: health plans must meet factor 4 of HO 5, Elements A and B regardless of CDO status. Begin working with your contracted care sites now to understand what information they can provide about accessible equipment and disability-related accommodations. Element A requires a documented process, reports, and materials and Element B requires a documented process and materials. Although this is wonderful information that is needed by members, it is a huge administrative burden. It would be great if the individual states could broker this information.

What this means for your organization

Start provider outreach now. Ask your contracted care sites what information they can share about accessible equipment, physical accessibility, and disability accommodations. This will inform your compliance with HO 5, Elements A, B, D, and E — four of the five elements in the standard.

3.  HO 6: Program Description and Evaluation Updated

The two elements in HO 6 (Program to Improve Service Appropriateness and Accessibility, formerly HE 5) carry targeted but meaningful revisions:

• HO 6, Element A (Program Description) — a new factor 2 is added (A description of the program’s structure). Stem and factor language revised to include accessibility instead of culturally and linguistically appropriate services. The scope of review and the look-back period was updated to “Prior to the survey” because of additional requirements, The program description must now reflect the expanded scope of the 2026 standards, including disability accommodations.
• HO 6, Element B (Annual Evaluation) — stem and factor language revised to align with updated program scope. The 3.30.26 Policy publication changed Renewal survey scope to the organization’s most recent annual written evaluation report and the look-back period to at least once in the prior year.

Organizations should review their existing CLAS program descriptions against the updated HO 6 requirements. What satisfied the former HE 5 program description may not satisfy the new factor 2 in HO 6, Element A as wording changed from “culturally and linguistically appropriate services” to “appropriateness and accessibility of its services.”

4. HO 7: Updated Measures and a Sharper Focus on Proving Interventions Work

The disparities measurement standard carries three significant changes:

• HO 7, Element A (Reporting Stratified Measures) — the former five-measure stratified reporting set (Colorectal Cancer Screening, Controlling High Blood Pressure, HbA1c Control, Prenatal and Postpartum Care, and Child and Adolescent Well Care Visits) is expanded with using four HEDIS measures selected from the 13 specified in the Explanation that must be stratified by race and ethnicity, thereby allowed the organization to choose what is most applicable (and probably in sync with organizational initiatives and population).
• HO 7, Element B (Stratifying Measures to Assess Disparities) — factor 3, which required analysis by gender identity and/or sexual orientation, is removed. New factors 4–6 are added, introducing disability, geographic, and two other new stratification dimensions (one HEDIS, one CAHPS measure of the organization’s choice). This element has been substantially restructured.
• HO 7, Element D is renamed from Use of Data to Measure CLAS and Inequities to Evaluating Effectiveness of Interventions. The title change signals the intent: NCQA now expects organizations to demonstrate not just that they identified disparities and implemented interventions, but that they evaluated whether those interventions actually changed outcomes. The 3.30.26 Policy Changes allowed for Initial and Renewal Surveys the documentation for factors 5 and 6 allows for submission of a plan for evaluation of interventions instead of an assessment report. These factors require the evaluation of whether interventions changed outcomes. 

'Evaluating Effectiveness of Interventions' is not just a new name. It reflects a fundamental shift in what NCQA expects — proof that your quality improvement work is working, not just evidence that you did it. 

 ADDITIONALLY, the 3.30.26 Policy changes specified that Element A may not be delegated.

 5.  HO 8: Delegation Requirements Revised Across the Board

All four delegation elements (formerly HE 7) carry revisions to look-back periods and/or scoring:

• HO 8, Element A (Delegation Agreement) — scoring updated, look-back period revised.
• HO 8, Element B (Predelegation Evaluation) — look-back period revised.
• HO 8, Element C (Review of Performance) — look-back period and explanation revised.
• HO 8, Element D (Opportunities for Improvement) — scoring and look-back period revised.

Organizations that delegate health equity activities should audit their current delegation agreements and oversight records against the updated requirements before their next survey for what is delegated. If delegation was specified by standard and element, make sure to crosswalk changes. If you’re an MHR client, you received the 2025- 2026 standards crosswalk that we did. 

Otherwise the delegation standard remains essentially the same.

Ready to get started?

Our team specializes in helping MCOs navigate NCQA practitioner network requirements and delegation compliance under the 2026 standards. Reach out to schedule a readiness conversation: [email protected] or set up a call here: https://zc.vg/2wWmh.  

© Managed Healthcare Resources, Inc. 2026

Next in this series: Blog 3 covers the Community-Focused Care Accreditation — specifically how the data collection and cross-sector partnership standards changed from Health Equity Plus, including the new critical factor in Element D.