Submitted on April 3, 2018
Date Time: 04/03/2018 04:12 PM
Product: Proposed Standard Changes for Health Plan Accreditation 2019
Topic: UM Standards: Must-Pass Elements Scoring
Element: What potential challenges, if any, might this change create for organizations?
Support Type: Support with modifications
Comment: Changing the scoring for the UM must-pass elements is certainly raising the bar for health plans. ACAP does not oppose raising the bar per se, but we do have concerns on the way NCQA is implementing this change.
First, the must-pass scoring threshold has been raised very quickly in a short period of time. In addition, given issues such as look-back periods, there should be greater notice in advance of this type of change. If NCQA chooses to move in this direction, it should not be adopted until July 2019. This would provide health plans adequate notice of the change.
Second, there is no clear guidance as to what the scoring methodology is to meet the 80% rate, since NCQA will not share the scoring options as part of the proposal process. Specifically, what is the threshold for an 80% must pass rate? In reality, we are concerned that closer to a 100% rate will actually be required to meet the 80% standard.
Third, we believe that the scoring should be different for plans going through a first-time survey and renewal surveys. We think the 50% must-pass rate should apply to first-time surveys and the higher 80% rate should be applied for renewal surveys.
Finally, we do not support immediately converting the accreditation status to a public-facing provisional status. We support allowing plans to submit and implement a corrective action plan before public action is taken. If the plan does not submit and implement a satisfactory CAP, then it could be converted to a public facing action and provisional status, but not before. Therefore, ACAP can only support this change if it is modified to address the above concerns.