C-OPIN 4-1: Delegation Management
This standard sets forth what appear to be simple requirements regarding how your organization manages the delegation process. In short, it says that if your organization delegates functions that are within the scope of your URAC accreditation, it retains accountability for compliance with URAC standards regarding those functions and conducts periodic oversight of the performance of the delegated contractor to ensure URAC compliance.
While this seems straightforward, it could use a bit of explanation.
First, what does URAC mean by "delegation"? An easy way to think about it is this:
If, in the non-Core portion of the applicable accreditation standards, tells you to do something, or tells you how to do something, and you contract with another organization (not an individual) to do that something, that's delegation.
So, once you've decided that, you simply need to be accountable for making sure the delegated contractor complies with the applicable URAC standards. You do that in the vetting process, the contracting process, and the ongoing oversight process, unless the contractor is URAC-accredited, in which case, you need only have a valid delegation agreement with the contractor.
This one standard replaces the former Core 6-9, and in some ways is more flexible about how you conduct delegation oversight. However, the interpretive guide provides some detail that used to be in the standards.
So, let's look a bit more closely at the details:
- Gone are the 8 elements telling you what needs to be in your delegation agreement. In their place is this simple edict: the agreement must describe the functions that the delegated contractor will be performing.
- If your contractor is URAC-accredited, your delegation agreement must require the contractor to notify your organization, promptly, of any change in its URAC accreditation status.
- Make sure the contract makes it clear the identity of the person or role in charge of oversight of the delegated contractor
- If the contractor is URAC-accredited or certified
- You must conduct periodic validation of the accreditation status.
- If the contractor is not URAC-accredited or certified, you need to implement a plan for the oversight of the contractor's performance.
- You may not delegate the oversight of compliance with URAC standards
- You clearly define the "how" and "when" of oversight mechanisms such as reports, audits, and the like
- Your plan uses a compliance rating scale
- You need to document your active management of the compliance with URAC standards by the delegated contractor
Submit, at a minimum:
- a template or sample delegation agreement (omit the financial information)
- a template or sample statement of work for such agreements
- proof of verification of URAC accreditation or certification, where appropriate
The reviewer will interview those members of both management and frontline staff who oversee delegated functions.
The reviewer will examine documentation of oversight of delegated functions, including meeting minutes, reports, audit results, and other methods of oversight specified in the oversight management plan.