Consumer Communications

Health Plan, Version 6.0 P-MR 8-Urgent Telephone Access


The Basics

This standard requires that your organization providing 24/7 means of access for your consumers and they're treating providers in the event of urgent healthcare issues.  That access needs to be via a toll-free telephone line.  Your organization may address this issue in part by providing for the participating primary care physicians to serve as the organizational representative when your offices are closed.  If your organization does delegate responsibility to non-employees, those representatives must have authority to act as a representative of the organization. Whether that is the approach your organization takes or not, you should be familiar with the policy, and know that the essential point here is that consumers and providers be able to find somebody who can talk on behalf of your organization at all hours.

Management Tips

Make sure your communications plan is explicit on how it handles after hours calls.  Also make sure that your provider contracts support any delegation of after-hours called responsibility.  Your providers must have the authority to bind your organization if they are acting on behalf of your organization under this standard.  Make sure that if a provider does act on your behalf as a delegate, you don't deny the benefit.  An example of this might be if such a provider refers consumer to seek emergency care at a particular facility.  You may not go back later and deny that care.

It is permissible to play a recording after hours to direct consumers to the appropriate health service.

URAC Accreditation Tips

This standard is weighted 4.

For the desktop review, submit your communications plan.

During the on-site review, the reviewer will interview managers in your organization of irresponsibility of implementing this dimension of the communications plan.  In addition, the reviewer is likely to call as a "secret shopper" to be sure that there is 24/7 coverage.

Health Plan, Version 6.0 P-MR 7-Scope of Telephonic Services


The Basics

This standard establishes four requirements for the service that is provided via the customer service toll-free telephone line described in the previous standard.  The services include:

  • responses to inquiries about benefit verification and eligibility;
  • help with finding providers in your network;
  • answers to questions about claims; and
  • accepting consumer complaints.

It will be important not only that you are familiar with your organization's policies and procedures regarding how these services are provided, but also the tools used in the provision of those services, such as consumer call logs and any scripts to help with delivering those services.

Management Tips

Make sure your communications plan is explicit on all four requirements of this standard.  The reviewer will reject it on desktop review if it doesn't clearly outline how you address all four issues.  In addition, it is incumbent upon you to provide documentation that you have trained your customer service representatives on how to handle all four types of inquiries.  Finally, while it is not required by the standard, it will help things greatly if you have a comprehensive consumer call log that provide some detail about how each call was handled and resolved.

URAC Accreditation Tips

Two of the elements of this standard are mandatory; the other two are weighted 4.

In addition to the communications plan, on desktop review you should submit customer service representative training records (including agenda and attendance sheets), a sample of your consumer call log, samples of any template correspondents used by the customer services department, and sample telephone statistics.

During the on-site review, the reviewer will both interview and observe customer service representatives taking calls.  During that observation, he/she not only will ask questions of the customer service representative, but also will assess whether the customer service representatives have the appropriate tools to handle all four types of inquiries described in this standard.

Health Plan, Version 6.0 P-MR 6-General Telephone Access


The Basics

This standard requires that your organization provide to consumers access to a toll-free line at least 40 hours per week.  That line must be open between 9 a.m. and 4 p.m. each business day in each time zone in your service area.  The only exceptions to that would be time zones in which you have fewer than 2% of your consumers.  Your organization no doubt has a policy and procedure that establishes the specific hours your organization's toll-free line is available.  Make sure you're familiar with it in addition to the standard.

Management Tips

Your communications plan should specify the hours of availability for your toll-free telephone line.  In addition, he should be able to produce documentation demonstrating what percentage of your consumers are in each time zone in your service area.  Furthermore, your communications to consumers should include your toll-free telephone line's hours of operations.  Be sure that your communications plan and those consumer communications agree with each other regarding those available times.

URAC Accreditation Tips

This standard is weighted 4.

For the desktop review, submit your vacations planned or P&Ps specifying your toll-free telephone line's available hours.  In addition, you should submit a sample of consumer communications that provide the hours of that line.

During the on-site review, the reviewer is likely not only to interview your customer service managers about the standard, but also to place "secret-shopper" calls to that number to make sure that you are implementing your policies and procedures.

Health Plan, Version 6.0 P-MR 5-Provider Network Directory Mechanism


The Basics

This is standard requires that your communications plan provide that, upon enrollment in one of your organization's benefit plans, a consumer is provided with a means of accessing it a participating provider directory.

In addition, your communications plan must assure consumers of ongoing access to up-to-date participating provider lists.  This might take the form of a phone number to call to talk to a customer service representative, the provider directory on the website, or some similar constantly-updated provider list.

Management Tips

Make sure that your communications plan addresses all of the ways that you provide your provider lists to consumers, both upon enrollment and on an ongoing basis.  Furthermore, it will be important that your customer service representatives are up-to-speed on all the various mechanisms that you have in place to provide such information.  Make sure your training covers it.

URAC Accreditation Tips

The two elements of the standard are weighted 4.

For the desktop review, provide not only your communications plan, but also documentation of the implementation of the plan, such as correspondence with consumers about updated provider lists, a screenshot of your online provider directory, and consumer information with your organization's toll-free number that consumers can call in order to find participating providers.

The on-site review will be an interview of both managers and staff members in the customer service department.  This places a premium on training on the standard and your policies that implement it.

Health Plan, Version 6.0 P-MR 4-Covered Benefit Disclosure


The Basics

This standard requires that your organization's communications plan explicitly provide that you inform consumers before you make changes in their covered benefits.  They must receive the notice before the change goes into effect.

An example of this would be in the event that he changed the copayments on one of your benefit plans.  You either need to send notice directly to the consumer, or have an assurance from the consumer's employer or the plan sponsor that it will give notice to the consumer in a timely manner.

Management Tips

This is one of those standards where it is not sufficient to do the right thing; rather, you must also have a policy and procedure that requires that you comply with the standard and describes how you will do it.

URAC Accreditation Tips

This single-element standard has a weight of 4.

For the desktop review, submit your formal communications plan, a summary listing of all benefit changes in the last two years (including the date of those changes), and sample correspondence to consumers regarding such changes.

During the on-site review, the reviewer will talk to customer service managers to confirm their understanding and implementation of your communications plan.

Health Plan, Version 6.0 P-MR 3 - Consumer Communications Plan


The Basics

This standard places an affirmative obligation on your organization to include in its consumer communications plan specific provisions on providing consumers with materials to explain:

  • how to receive help via e-mail, telephone, or in person;
  • covered benefits;
  • accessing covered benefits (including prior authorization requirements, special information for emergencies and receiving services when out of the organization's service area, and drug formulary);
  • cost sharing mechanisms in your benefits plan;
  • instructions on how to find out the cost of covered benefits;
  • any responsibilities imposed on the consumer to cooperate with the organization's medical management programs;
  • benefit exclusions;
  • instructions on how to obtain evidence-based health information;
  • directions on how to pursue complaints and appeals.

It will be important that you have access to a current copy of the communications plan and are familiar with how it addresses these issues.

Management Tips

Make sure that you don't rely exclusively on Internet access to comply with the standard.  Not everybody has a computer, and you're obligated to document how you will get this information to folks who don't.

URAC Accreditation Tips

Most of the elements of the standard are either mandatory or weighted 4.  One element, addressing information about the cost of covered benefits, is a Leading Indicator.

Naturally, the communications plan will be the central document that you submit for desktop review.  In addition, the documents that demonstrate compliance with your policies and procedures as articulated in the communications plan, such as member rights and responsibilities documents, newsletters, correspondence, or member handbook would be a good accompaniment to that plan.  In addition, documentation of training of employees and consultants in the requirements of the standard also would be helpful.  Remember, keep the number of documents you submit to nine or fewer.

During the on-site review, the reviewer will examine recent enrollment materials and documentation of how you handle consumer complaints and appeals.  In addition, interviews of marketing and customer service managers and staff members will cover not only their understanding of your policies and procedures, but also how thoroughly they've been trained.

Health Plan, Version 6.0 P-MR 2 - Consumer Information Disclosure


The Basics

This standard requires that your organization make available to consumers a rather extensive and specific list of items of information about your organization and its services:

  • a description of the mechanisms by which your organization provides information for consumers for whom English is a second language or who have special needs, such as cognitive or physical impairments;
  • a list of network providers;
  • general descriptions of your compensation arrangements for participating providers;
  • any tools that your organization makes available to consumers to help them in managing their own care;
  • statistics about consumer satisfaction with your organization's services;
  • administrative requirements;
  • requirements regarding medical management (UM, CM, DM);
  • health benefits;
  • any financial responsibilities that your health plan imposes on consumers, such as deductibles, co-pays, co-insurance, etc.;
  • any responsibilities that consumers bear for health benefits decision-making;
  • any criteria for benefits that her condition-specific; and
  • information about coordination of benefits.

Your organization no doubt has detailed policies and procedures addressing all of these points.  Make sure that you are familiar with those policies and procedures, and not just this standard's requirement.

Management Tips

Notes that you don't have to post all of this information in public places.  For example, you may choose to provide the provider compensation arrangements and consumer satisfaction statistics only upon request.  However, if you take that option, you must make sure that your customer service representatives and any other members of the staff who might be recipients of such a consumer request are fully trained on how to respond to those requests.  Furthermore, the provider compensation information described in this standard does not have to address specific compensation amounts; rather, it may provide a general description (e.g., capitation, fee-for-service).

URAC Accreditation Tips

All of the elements of the standard are weighted 4.

For the desktop review, submit written policies, consumer materials like a member handbook or a summary benefit plans, a portion of the provider directory, a screenshot from your consumer portion of your organization's website, evidence of training in the standards, and the results of consumer satisfaction surveys.  This is a lot, so be strategic so that you keep your documents and to submit to nine or fewer.

The on-site review will involve a thorough documentation review of consumer education materials and the organization's website.  In addition, the interviews will be conducted of senior management, marketing personnel, and customer service managers to assess understanding of all elements of your applicable policies and procedures.  In addition, the reviewer is likely to call your customer service representatives to see if they know how to respond to requests for information covered by the standard.

CORE, Version 3.0 CORE 40 - Health Literacy


The Basics

This standard, a new, experimental standard, suggests that your organization should have policies and procedures that address health literacy.  In this context, the meaning of health literacy is, "The degree to which individuals have the capacity to obtain, process, and understand basic health information and services needed to make appropriate decisions regarding their health."  The three suggested elements are:

  • making sure the consumer materials are in plain language;
  • measuring the extent to which the organization's consumer documents use plain language; and
  • training staff members who interface with or write content for consumers.

Your organization may or may not have such a policy and procedure.  The standard is not required, yet, but likely will be in the future, so your organization may be developing a health literacy policy and procedure in anticipation of when this becomes a standard that is no longer optional.

Management Tips

The elements of this standard are known as Leading Indicators.  While they are worth no points in the accreditation calculation, URAC does want applicants to develop a policy and procedure for this issue, even if it is not yet implemented.  In light of the fact that this is likely to be a standard with point value as early as 2011 or 2012, we recommend that you develop the policy and procedure now, and begin implementing it over the next two or three years, if you do not currently have a health literacy program.

URAC Accreditation Tips

All three of the elements of the standard are leading Indicators.

For the desktop review, submit any policies and procedures addressing health literacy in consumer materials, as well as a policies and procedures that address staff training around this issue.  In addition, if you have any written materials already developed that incorporate health literacy in plain language, you should submit that, too.

During the on-site review, the reviewer will look for evidence of implementation, including a demonstration in communication materials have been reviewed and approved as complying with the health literacy in plain language policies of that organization.  In addition, the reviewer will interview program management and staff members to assess the extent to which you have implemented your policies and procedures regarding health literacy and plain language.

CORE, Version 3.0 CORE 37 - Consumer Rights and Responsibilities


The Basics

This standard requires that your organization implements a mechanism to inform consumers of rights and responsibilities relating to your services.  That mechanism should include specific guidelines for how and when the organization will advise consumers of those rights.  As a member of the staff, it will be incumbent upon you to know what your organization's policies and timelines contemplate regarding this notice.  

Management Tips

As you develop your policies and procedures around this, you have a good deal of flexibility.  URAC as a general preference, expressed in other standards, for multi-modal communications.  So, you may want to consider website, regular mail, or e-mail as modes of communication.

This standard will not apply the organization if you have no interface with any consumers.

URAC Accreditation Tips

This standard has a weight of 4.

For the desktop review phase, submit your policies and procedures describing your modes of distributing consumer rights and responsibilities.  In addition, you can submit sample newsletters or screenshots of Web pages.

During the on-site review, the reviewer will examine your documentation demonstrating that you've implemented these policies.  Furthermore, he/she will interview members of your staff who are involved in communicating with consumers.