By Nancy Ross Bell, RN
Estimated time to read: 4 minutes
If you are one of the 164 organizations accredited for NCQA Health Equity (HEA), one of the 18 in process, or one of the 73 scheduled for a survey*, chances are you may also be thinking about the next step to Health Equity Accreditation (HEA) Plus (+), which builds upon the HEA standards and takes organizations further into communities.
* NCQA Report Card - Other Health Care Organizations– July 15, 2024
This blog highlights select requirements to demonstrate the depth and breadth of expanded data needs, reporting requirements, collaboration and integration with community partners, and the importance of external stakeholders to interventions.
As always, please refer to NCQA’s current year HEA and HEA+ standards and guidelines, policy updates, and FAQs for complete details on all requirements.
If you are a Health Plan, Managed Behavioral Health Organization (MBHO), Utilization Management (UM), Case Management (CM), Wellness entity, hospital, hospital system, community-based organization or clinic, or a Federally Qualified Health Clinic (FQHC), and are planning for accreditation in health equity, then this blog is for you!
Key Takeaways
Points and Look-Back Periods for HEA+:
- 5 Elements are worth 2 points each to Meet (HEA+ 3 C, 4 CD, 5 BD), with the remaining being 1 point each.
- 15 Elements have no points available for Partially Met, meaning if the Element is not fully Met, then zero points are awarded.
- Most (not all) look-back periods are 6 months for Initial Surveys and 24 months for Renewal Surveys. Several differ, so be sure to review each standard.
Organizational changes:
Organizations considering a merger, acquisition, or consolidation (MAC) must follow NCQA’s policy on evaluating these transactions (Appendix 3+ MAC Policy for HEA Plus).
Reporting for HEA+:
Reporting for HEA+ is required for both Initial Surveys and Renewal Surveys. For some standards, a detailed implementation plan may be accepted for Initial Surveys since “annual” reports may not be ready.
- Annual data analysis identifying prioritized risks of communities and prioritized needs of individuals
- Program description that is approved by a governing body approved by a governing body (HEA+ 4A)
- Annual work plan that is approved by a governing body (HEA+ 4B) and
- includes SMART goals (specific, measurable, achievable, reasonable, and a timeframe to complete). (HEA+ 4A.1 Explanation)
- Annual program evaluation of effectiveness with trending measures to assess goals, barrier analysis, and overall effectiveness (HEA+ 4E 1-6). For Initial Surveys, a detailed implementation plan may be submitted (HEA+ 4E Scope of Review, Explanation)
- Annual evaluation of external stakeholder engagement
- Annual partnership assessment
Documented processes for HEA+:
Documented Processes are required for 15 Elements, which largely must be in effect throughout the look-back period. However, additional policies or procedures may be necessary to help clarify the organization’s operations.
High priorities for HEA+:
- Identifying communities
- Collecting detailed data on communities and individuals
- Developing a program description and annual work plan
- Securing at least one community partner agreement, or for an Initial Survey, an existing agreement with a plan to update may be submitted (HEA+2 D Explanation)
- Engaging and involving external community stakeholders
- Implementing and communicating privacy and security practices of individual-level data. For Initial Surveys, a detailed implementation and communication plan with timelines and sample communication may be submitted in lieu of a report (HEA+3 C Scope of Review)
Data (HEA+ 1 A and HEA+3 A-C)
- With HEA, individual-level data on race/ethnicity, written and spoken languages, gender identity, and sexual orientation is already collected.
- With HEA+:
- Data needs are expanded to include acquiring data on the broader populations within the communities they serve.
- Organizations must identify the communities they serve, which may be multiple, thereby requiring data on the populations of each.
- Data are analyzed for the social risks of each community and the social needs of individuals.
- As data is analyzed, individuals are grouped into one or more sub-populations based on characteristics, such as a geographical location and social unit that share commonalities.
- Because Protected Health Information (PHI) data is analyzed at the individual level, data management on security and privacy protections is critical. For example, system controls, permitted and not permitted uses of data, and how individuals can communicate how their preferences are shared are among the required documented processes.
Social risks are adverse social conditions associated with poor health outcomes, for example, social isolation, housing instability, or poverty. (Appendix 2+ HEA Plus Glossary)
Social needs are non-clinical needs individuals identify as essential to their well-being and related to their social risks. (Appendix 2+ HEA Plus Glossary)
While individuals may have the same social risks, their social needs may differ, requiring interventions to be addressed at the individual level.
Collecting, analyzing, and reporting data is a high-priority requirement for multiple standards.
Social Risks & Social Needs (HEA+ 1 B - F)
Data on each community defined by the organization must be acquired at least once from three different sources every three years (36 months), of which one source must be endorsed by a community partner (HEA+ 1D). One example of community-related data is the American Community Survey.
Partners are organizations that deliver social needs resources or interventions to individuals served by the organization (Appendix 2+ HEA Plus Glossary). For example, partners could be transportation services, social service agencies, or a town’s senior center.
Data on social needs must be collected annually on individuals. Organizations must follow a documented process to collect, retrieve, and report on data collected from multiple sources. Data on social needs includes:
- Financial insecurity
- Food insecurity
- Housing stability
- Access to transportation
- Interpersonal safety
- An additional domain, for example, discrimination, bias or racism, or access to technology-based services
Subpopulation data is segmented or stratified annually to identify and prioritize needs. NCQA explains that organizations are not required to mitigate every social risk and address every social need in every community in their service areas; rather, they need to determine areas of high need most affected by their interventions to lessen inequities. Additionally, organizations must provide rationale and conclusions on their selections (HEA+ 1 G, Explanation).
Partners and Programs (HEA+ 2, 3 & 4)
Organizations are required to assess their capacity and capability annually to provide the resources necessary according to a prioritized list of opportunities to mitigate social risks and support social needs. If organizations do not have the internal resources to address individuals' needs, agreements with community partners can be secured to directly intervene or collaborate on support.
In reality, many community entities have already been doing this needed work, and it is incumbent on the organization seeking NCQA Accreditation to collaborate with the community entities to continue their work and partner with them to assess the impact. (HEA+ 2C)
As partners are selected, the organization must establish a written, mutually agreed-upon contract or agreement with at least one partner (HEA+ 2D).
For Initial Surveys, where existing contracts or agreements are currently in place, the organization may submit a plan to update its agreement with the required factors. (HEA+ 2D Explanation)
Stakeholders (HEA+ 4 CD)
NCQA gives considerable importance to the role of external stakeholders, who are members of their communities and populations of individuals served. Organizations must engage external stakeholders and meaningfully involve them in intervening to address social needs.
Examples of meaningful involvement by external stakeholders include participation in committees, focus groups, functions, and work groups. Stakeholders can also provide input into program goals, selection of partners, and evaluation of program effectiveness.
Connecting Individuals with Timely Referrals to Partners (HEA+ 5 A-D)
With resources identified, individuals must be connected by timely referrals to partners with whom a formal agreement has been established for providing interventions. Organizations must ensure that referrals are facilitated, tracked, and assessed for outcomes to reduce disparities. For Initial Surveys, organizations may submit a detailed implementation plan for identifying referral statuses to identify disparities. (HEA+5 D Scope of Review)
Expectations of the organization, community partner, and individual being referred must be communicated. For Initial Surveys, in lieu of materials, organizations may submit a detailed implementation plan. (HEA+5 B Scope of Review)
Pulling it All Together with MHR’s Guidance!
MHR stands ready to guide you along your journey with NCQA’s Health Equity accreditations. We have the consultants, tools, templates, and training you need to prepare for a survey.
Call to Action:
- Before starting your look-back period, contact MHR to schedule a Discovery Call or training on Health Equity Accreditation or Health Equity Accreditation
MHR follows a quality review process for all blogs. This blog was written with expert input from Sonia Frazier, MHR’s Subject Matter Expert on health equity. Read more about Sonia and our other consultants at ManagedHealthcareResources.com/About Our Consultants.
MHR: Driving healthcare quality one NCQA accreditation at a time
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