Avoid Broken Links in Your NCQA Delegation Agreements

By Nancy Ross Bell, RN

Estimated time to read: 3 minutes

When you hear about broken links, you may think about hyperlinks that produce the dreaded error message of “Page not found.” What about the links that connect organizations to their delegates?  When links are broken in Delegation Agreements, poor member experience, forgotten responsibilities, lost revenue, and even lost points on your NCQA Accreditation Survey can occur.

MHR Consultants frequently see broken links in delegation when:  

• Staff are unfamiliar with NCQA delegation standards, including the benefits of delegating to accredited entities
• Individuals who wrote the Delegation Agreement are disconnected from the ones responsible for implementation and oversight
• Agreements lack specific details holding each entity accountable for their responsibilities
• Performance monitoring is weak, or issues are left unresolved

Avoid broken links by connecting the dots from the standards to binding Delegation Agreements to implementation and oversight.  Read this blog that focuses your attention on Element A, Factors 1 through 4, on Delegation Agreements. (Factors 5 and 6 are excluded in this blog).

What is NCQA Delegation?  

As a review, delegation is the following:

• An organization or health plan (delegating entity) gives or delegates authority to another organization (the delegate) to perform an activity it would normally do to meet an NCQA requirement
• The delegating entity is accountable for the delegate’s performance and must provide evidence of oversight
• If a delegate gives a third party the authority to carry out a delegated function, the specific details on responsibilities and oversight must be included in the Delegation Agreement between the delegating entity and the delegate

Delegation is not a document without designated responsibilities and accountabilities! 

The NCQA Delegation Agreement (Element A, Factors 1-4)

All delegation standards (utilization management, credentialing, population health, member experience, and quality improvement) include the same Factors 1 through 4 as follows:

The Delegation Agreement:

1. is mutually agreed upon
2. describes the delegated activities and responsibilities of the organization and the delegated entity
3. requires at least semiannual reporting by the delegated entity to the organization
4. describes the process by which the organization evaluates the delegated entity’s performance

As always, MHR refers you to the most current version of the NCQA standards for your program for complete details of all the Factors and Explanations.

Tips on Avoiding Broken Links

• Keep dates in sync. There are three dates to consider:
  • the date when a predelegation evaluation was completed (new agreements)
  • the date the binding document was signed
  • the date when activities or responsibilities are effective

Delegated activities may be implemented after the date of the conclusion of a preassessment and improvement opportunities are addressed (new agreements) and after the effective date of the binding document or after the date the binding document is executed. This ensures the organization is well aware of the delegate’s operational status before it assigns responsibilities of a service to its members.    

         Note: If new responsibilities are assigned after implementation of delegation, then the agreement must be updated with an effective date of the new responsibilities and a preassessment of those new responsibilities.

• Ensure Delegation Agreements include all the details and bullet points within the Explanations for the respective standard set. Note the new requirements for Information Integrity in the Utilization Management and Credentialing standards (Element A, Factor 4).

Don’t assume that all Delegation Agreements are the same. Standards vary, and so does the detail.

• Before a binding agreement is finalized, ensure that a critical review of all NCQA verbiage is completed by the appropriate individuals who are responsible for the relationship, oversight, and reporting.
• Ensure the agreement specifies the process for submitting reports, that reporting is at least semi-annual, and how and to whom the delegate submits reports (Element A, Factor 2).
• Ensure monitoring reports specify timelines and required detail (Element A, Factor 4). Sample reports with suggested data fields may be included as an appendix to the agreement.
• Ensure clarity of organizational relationships, such as delegation to subdelegates (Element A, Factor 2) or subsidiaries.
• Assign responsibility for checking existing Delegation Agreements and fine-tuning them as needed, especially when NCQA distributes Corrections, Clarifications, and Policy Changes to the standards.
• Conduct regular audits of your website where information about the delegates exists. Check the functionality of hyperlinks to ensure a smooth member experience.
• Communicate issues promptly and document resolution(s) in monitoring activities and oversight meeting minutes (Element A, Factor 4).

Consult with MHR and use our tools and templates to lessen the risk of broken links. MHR’s Delegation Suite for health plans includes audit tools specific for credentialing, member experience, network management, population health management, quality improvement, and utilization management.  Templates and summary reports for UM and CR Information Integrity are included in the 2025 Delegation Suite.

Also included within the Suite is a comprehensive guide for delegation oversight, a tracking grid for delegate reports, checklists for delegation agreements according to current standards, and a table to track vendor relationships.

Do you only need the tools for one standard set? We have that, too, at individual pricing.

When combined with MHR’s consulting and training, organizations have all they need to help ensure they maximize their scoring and potential automatic credit.   

Your Call to Action!  

Let’s face it. Most organizations have multiple delegation and vendor agreements. At times, it can be challenging to keep track of them all, knowing responsibilities can change, effective dates differ, and relationships between organizations and delegated entities change over time. MHR is your partner that objectively assesses where you are now and where you need to be.

Contact Your MHR Consultant to:

• Train your team on Delegation. Along with the accreditation leads and subject matter experts, this session is important for representatives from your legal, contracting, and IT departments, as well as your finance department, to understand the cost benefits of compliant delegates. Go to Training to schedule a session on Delegation by an MHR Consultant.
• Review and score your Delegation Agreements against the current standards, including requirements on Information Integrity.
• Audit a sample of files.
• Help clarify organizational relationships in the context of delegation, such as parent and sister relationships, sub-delegates, and vendors.
• Advise on possible automatic credit.

Not an MHR client yet? We would love to speak with you. Schedule a Discovery call through our Contact page and read about How We Work.

Read More About Delegation in These Blogs 

Delegating to an External NCQA-Accredited Health Equity Organization (11/15/2023)

Getting Delegation “Right” (1/18/2023)

MHR implements a thorough quality review process for all blogs. This blog features insights from Deborah Warren, RN, and Kim Carpenter Petit. Learn more about MHR’s Independent Consultants at managedhealthcareresources.com/AboutOurConsultants.