Delegation and Oversight Policy and Procedure
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Governs how Network Health Plans (NHP/NHIC) may delegate or sub-delegate credentialing and recredentialing responsibilities to external entities, and describes the criteria, audits, reporting, and oversight required of delegates. Affects delegated organizations, the Credentialing Department, and the Credentials Committee.
No material clinical or coverage changes in this revision.
Delegation and Oversight Criteria
Delegation and Oversight Criteria
Delegation and oversight of credentialing/recredentialing functions is allowed when the following procedural steps and criteria are met.
ALL of the following
- Credentialing Department requests current documents from the entity (e.g., applications, credentialing/recredentialing policies and procedures, bylaws, list of Credentials Committee members, minutes from three CC meetings, complete provider roster, and quarterly credentialing system audit reports).
- Credentialing Department reviews documents for compliance with NHP/NHIC, state, federal and NCQA standards and documents findings on the NHP/NHIC Credentialing Delegation Audit Tool.
If documents comply or do not comply
- If documents comply, an on-site visit may be scheduled within 30 calendar days (if applicable).
- If documents do not comply, audit results and a proposed corrective action plan (CAP) are sent to the entity; the entity has 30 calendar days to respond. If no response is received within 30 calendar days, credentialing/recredentialing functions may not be delegated.
ALL of the following
- When conducted, onsite reviewer will examine required elements and document results on the NHP/NHIC Credentialing Delegation Audit Tool.
Audit methodology
- Audit either 5% of practitioner files or 50 practitioner files, whichever is less; the sample must include at least 8 credentialing files and 8 recredentialing files (or audit the universe if fewer than 8 in the look-back period).
- Or use the NCQA '8/30 methodology' to review delegate files for credentialing and recredentialing.
ALL of the following
- NHP/NHIC sends a Delegation Agreement that delineates which entity performs each activity, reporting requirements, term of agreement, and remedies including revocation if obligations are not fulfilled. The delegated entity must return a signed Delegation Agreement within 90 calendar days.
- If PHI is involved, the Delegation Agreement must include a Business Associate Agreement, allowed uses of PHI, description of safeguards, sub-delegate safeguards, obligations to provide individuals access to PHI, notification of inappropriate uses, and provisions for return/destruction/protection of PHI at agreement end.
- Delegation Agreement must identify how NHP/NHIC will evaluate the delegated entity's performance and specify remedies available to NHP/NHIC, including revocation. Delegated entity must submit a list of practitioners/providers and required practitioner information with the Agreement.
ALL of the following
- Delegated entity must provide reports at least twice a year describing activities carried out to improve performance; reports are reviewed by the Credentials Committee and reported to the QMC as applicable.
- Delegated entity must monitor and inform NHP/NHIC immediately, or as defined in the Delegation Agreement, of all practitioner/provider sanctions by state licensing agencies, Medicare and/or Medicaid. NHP/NHIC reserves the right to approve, suspend, or terminate individual practitioners/providers and to terminate delegation where appropriate.
ALL of the following
- If the delegated entity is NCQA-certified/accredited, NHP/NHIC is not required to conduct an annual onsite evaluation but will annually verify continued NCQA status; NHP/NHIC may evaluate at any time with reasonable notice.
- Credentialing Department will schedule a virtual audit or onsite visit with the delegated entity annually and request updated documents (including list of practitioners/providers within the scope of delegation).
Regulatory Citations and Audit Thresholds
| 42 C.F.R. 422.503 | Medicare managed care requirements referenced |
| 42 C.F.R. 422.504 | Medicare requirements for delegation oversight (h-i subsections referenced) |
| 42 C.F.R. 423.504 | Part D oversight requirements referenced |
| 42 C.F.R. 423.505 | Part D requirements (b)(10)(h-i) referenced |
| 45 C.F.R. 155.20 | Marketplaces standards referenced |
| 45 C.F.R. 156.340 | Essential health benefits / credentialing reference |
Delegable Credentialing Activities
Delegable credentialing activities
NHP/NHIC may delegate the full range of credentialing and recredentialing activities to an external entity; delegated activities must be specified in the Delegation Agreement and carried out in accordance with NCQA‑approved sources and policy requirements.
- Accepts applications, reapplications and attestations
- Collects licensure, DEA and CDS information from NCQA‑approved sources
- Collects education and training information from NCQA‑approved sources
- Collects work history information from NCQA‑approved sources
- Collects history of liability claims information from NCQA‑approved sources
- Conducts site visits and medical record keeping review as applicable
- Collects licensure sanction information from NCQA‑approved sources
- Collects Medicare and Medicaid sanction information from NCQA‑approved sources
- Collects and evaluates ongoing monitoring information
- Makes credentialing/recredentialing decisions
- Provides practitioner and provider input and Credentials Committee meeting minutes
- Provides at least twice‑yearly reports on activities to improve performance
- Provides quarterly ECHO Credentialing system audit reports
Definitions
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