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Here’s something we’re already seeing in the field: health plans reviewing their 2026 renewal checklist, spotting QI 2C for the first time, and assuming it’s a minor administrative add-on. Something to tidy up before submission. A form to sign, a box to check.

It is not.

QI 2C – Behavioral Health Data Sharing Arrangements is a scored, all-or-nothing element, effective July 1, 2026. That means Met or Not Met—no partial credit, no room for “we had something in place but didn’t document it well.” This element affects only Renewal Surveys for all lines of business except for the Exchange product with a “prior to the survey” look-back period.

We’ve watched organizations get tripped up by requirements like this before—not because they weren’t doing the work, but because they hadn’t formalized it in a way NCQA can see and score. Don’t let that be your story in 2026.

Let’s walk through exactly what QI 2C requires, what counts as evidence, and what you need to do right now.

Why This Element Deserves Your Immediate Attention

The scoring weight alone should get your attention.

Missing QI 2C can represent:

• 6% of the Medicaid QI score when there is delegation
• 7% of the Commercial or Medicare QI score when there is delegation
• Even more without delegation

And remember—organizations must still achieve at least 80% in each standards set to avoid a Corrective Action Plan (CAP). A single “Not Met on an element this size can put you uncomfortably close to that threshold.

 A few important parameters to know upfront:

• QI 2C applies to Renewal Surveys only. It is Not Applicable for First and Interim Surveys.
• It is also Not Applicable if your organization does not contract with a behavioral health organization.
• QI 2C may not be delegated.
• Bi-directional data sharing is not required.

What QI 2C Actually Requires

At its core, QI 2C requires three things:

1. At least one active data-sharing arrangement with a qualifying behavioral health organization
2. Data sharing on at least one designated HEDIS measure per product line
3. Proof that data was actually shared during the 12-month look-back period prior to survey

That third requirement is where organizations most often fall short. Having an agreement in place is necessary—but it’s not sufficient. NCQA wants to see that the arrangement is operational, not just documented.

Which Organizations Qualify as Behavioral Health Partners?

If your organization contracts with any of the following, QI 2C likely applies to you:

• Managed Behavioral Health Organizations (MBHOs)
• Inpatient psychiatric facilities
• Behavioral health clinics

When in doubt, review your contracts. If you’re contracting with a BH entity and serving a product line that includes a Renewal Survey, assume QI 2C applies until you confirm otherwise.

Choosing Your HEDIS Measures

NCQA identifies 14 designated behavioral health-related HEDIS measures eligible for QI 2C.

These generally fall into four categories:

• Treatment and engagement
• Follow-up care
• Screenings and monitoring
• Medication management

You need at least one measure per product line—but choosing strategically matters.

At MHR, we advise clients to prioritize:

• Measures where your performance has room to improve
• Measures with meaningful impact on your covered population
• Measures already embedded in existing QI initiatives, so you’re not creating parallel work

The goal isn’t just to check the box—it’s to select measures where the data sharing actually drives improvement. NCQA can tell the difference.

What Evidence Do You Need?

Evidence for QI 2C is two-fold, and both pieces must be present and clearly defensible.

Part 1: A Documented Data-Sharing Arrangement

This isn’t a template you pull from a file on survey week. NCQA wants to see a real, implemented process.

Your documentation should clearly describe:

• Who is responsible for oversight
• Who is accountable for sharing the data
• Who is accountable for receiving the data
• How HEDIS measures are selected for each product line
• How data will be transmitted (reports, secure data feeds, etc.)
• The timeframe when data is scheduled to be shared

Acceptable forms of documentation include policies and procedures, process flow charts, protocols, or other written mechanisms that describe the operational process. Evidence that the arrangement is in place can include email communication, a memorandum of understanding (MOU), or relevant contract language.

The key: documentation must reference the specific HEDIS measures included in the arrangement. This is not a suggestion, and generic language about “data sharing” won’t meet the standard.

Part 2: Proof That Data Was Actually Shared

This is the piece that catches organizations off guard. You need documentation showing that the data sharing actually happened during the look-back period—not just that you had an agreement saying it would.

Examples of acceptable evidence include:

• Pharmacy data reports
• Readmission reports
• Follow-up after emergency department visit reports
• Screening and monitoring reports

Whatever you submit must clearly align with the specific HEDIS measure(s) named in your arrangement. The connection must be explicit.

Your Action Plan: Start Here

Because of the 12-month look-back, timing is everything. If you wait until the month before your survey to formalize this, it will be too late—and you will receive a “Not Met.” We know changing agreements takes longer than one might think, so waiting for the last minute will not bode well for you. Remember the “Met” or “Not Met” only scoring? Even if you have the process specified, if you don’t have the agreement and don’t show evidence that data was shared, expect a “Not Met.”

Work through these steps now:

1. Confirm you have at least one active contract or arrangement with a qualifying BH organization
2. Select at least one of the 14 designated HEDIS measures per product line
3. Update contracts, MOUs, or formal documentation to name the specific HEDIS measure(s) and the method of data sharing (after discussion with the organization)
4. Develop or formalize your documented process, including the who, what, when, and how
5. Implement data sharing within the required look-back period
6. Retain reports and supporting materials as survey evidence

Don’t wait. A “Not Met” on QI 2C is entirely preventable—but only if you start early enough for the look-back period to work in your favor.

Build QI 2C Into Your Broader QI Program—Not Around It

The organizations that handle QI 2C best are the ones that don’t treat it as a standalone compliance item. When you integrate it properly, it strengthens your entire QI program.

Best practices we recommend:

• Document new BH data-sharing arrangements in QI Committee minutes
• Maintain a tracking log of shared data and timelines. 
• Monitor HEDIS measure performance collaboratively with your BH partners
• Review selected measures annually to ensure they remain the right fit
• Align BH data-sharing efforts with your population health and UM initiatives

When QI 2C is woven into how your organization already operates—rather than bolted on before survey—it drives real cross-organizational accountability and measurable improvement in behavioral health outcomes. That’s the intent behind the standard. And NCQA will be able to tell whether you’ve reached it.

MHR Can Help You Get This Right

The 2026 NCQA standards are raising the bar across the board—and QI 2C is one of the clearest examples of a requirement where early action and precise documentation make all the difference.

• Ask your MHR Consultant to review your QI 2C evidence and documentation for survey readiness
• Schedule your team for MHR’s training on the 2026 QI standards: Reach out to us here
• Explore MHR’s library of resources, tools, and templates built specifically to support QI 2C implementation: https://www.managedhealthcareresources.com/tools

Contact us at [email protected] 

or visit managedhealthcareresources.com to get started.