The Basics

This standard sets forth the requirements for your delegation oversight mechanisms for your contractors that are not URAC-accredited.  For each such non-accredited contractor, you must:

• conduct a periodic review (at least yearly) of your contractor's policies and procedures, as well as any documentation about quality improvement activities regarding the delegated functions;
• verify (at least annually) that your contractor is complying with the requirements of your delegation agreement and applicable P&Ps; and
• make sure that any financial incentives employed by your contractor do not compromise quality of care.

The trickiest of these elements is the last one.  You need to have a documented procedure to, first, know whether your contractor has financial incentives for its employees or agents.  If, as a result of your inquiry, you learn that the contractor does employ such incentives, you then need to document that you have conducted sufficient oversight to be comfortable that the incentives in no way compromise the well-being of patients.

Management Tips

The management key for this standard is documentation of oversight.  Most URAC-accredited companies keep all the documentation regarding a delicate in a dedicated binder.  Behind each tab (clearly marked, of course) are such documents as pre-delegation audits, the delegation agreement, reports submitted by the contractor regarding its performance under the delegation agreement, documented evidence of your organization's periodic review of the contractor's P&Ps, documentation of your compliance oversight process, and finally, documentation of a review of any impact financial incentives may have on patient care.

URAC Accreditation Tips

The element of the standard that addresses financial incentives is a mandatory element.  The other two elements are each weighted 3.

The documentation required to be submitted with the initial application is simply the applicable delegation oversight  P&P.  just make sure that it contains all the required elements of this standard.  In addition, it would be prudent to submit any templates for audit mechanisms you may use in the implementation of that policy.

As was the case with the previous three standards, delegation binders will be the focus of the reviewer's attention during the on-site review.  The reviewer will have an expectation that those binders are complete, well-organized, and clearly marked.