Communications

CSCD 6 provides:

The organization provides telephonic access to clinical personnel and provides a system for telephonic communication for participating consumers and providers:  (No Weight)
    (a) At least 12 hours a day during business days in the time zones for its service area: (4)
        (i) Services for consumers, 7 days a week, from 8 am to 8 pm; (4)
        (ii) Services for pharmacies should be the same hours, which network pharmacies are open and provides information on claims processing, benefit coverage, claims submission and claims payment; and (4)
        (iii) Services for physicians and other prescribers, should not be less than 10 hours, such as 8 am to 6 pm; (4)
    (b) Normal business hours for routine calls with access to appropriate clinical personnel; (4)
    (c) Outside hours of operation, telephone service will be available 24 hours/7 days per week for urgent and emergent calls; and (Mandatory)
    (d) Has clearly specified hours of operation that are communicated to consumers and providers. (4)

Unlike the previous two standards, which focused on communication with your organizational clients, this standard is focused on communicating with consumers, pharmacies, physicians, and other prescribers. 

Note that not all mail service pharmacies contract to provide call center services.  If this is the case with your organization, submit an attestation to that affect and this standard will be "not applicable."  

However, if this standard does apply to you, it sets detailed requirements for the hours of operation of the call center, different requirements depending on whether the caller is a consumer, a pharmacy, or a prescriber.

If the language of subsection (a) is confusing to you, fear not.  It is not you -- it is the standard, which is not URAC's finest literary effort.  At first glance, the stem for (a) would seem to suggest that all three caller categories get 12-hour access, but that seems clearly the case only for consumers.  The hours for pharmacies seem to be longer or shorter, depending on which hours "network pharmacies are open."  Finally, prescribers are guaranteed only 10 hours of access, the language of the stem notwithstanding. 

The standard requires that your clinical staff be available for these three caller types during normal business hours, and 24/7 coverage for emergency services. 

With no apparent irony intended, the standard requires that you communicate, clearly, your policy on hours of operation to consumers, pharmacies, and prescribers.  

For this standard, submit a P&P that describes in detail your communication policy for all three caller groups including not only hours of operation, but how you are going to handle staffing, both during normal business hours and after-hours, as well as emergency calls, non-English speaking callers, and callers with rotary phones.

This standard provides:

The wellness organization provides communication materials about the wellness program to the target population to engage potential program participants. The materials: (---)
(a) Inform and educate the target population about how the wellness program works; (4)
(b) Describe the benefits, the potential outcomes, and the interventions associated with the wellness program; (4)
(c) Are accessible to the target population through multiple formats; and (4)
(d) Address cultural sensitivity differences within the target population. (4)

This standard will be paired up with Core standards dealing with communications activities (Core 21 in particular). While the Core standards will require the implementation of mechanisms to ensure accuracy of the information provided to consumers, this standard delineates the level of detail in those communications (e.g., how the program works, benefits, potential outcomes, and associated interventions).  

Additionally, this standard requires the wellness organization to provide target population with materials accessible in multiple formats, such as electronic, paper, or mass-communication techniques.  In addition, the organization will be required to take into account the cultural issues that may affect how that communication is to be made effective for the target population.

It is worth noting at this point that "target population", new to the URAC vocabulary, is different than the commonly used "consumer."  URAC defines it as follows:

The group of individuals, as defined by the purchaser, who are eligible to become participants in the wellness program. The target population may be defined broadly (e.g., all employees regardless of health status) or narrowly (e.g., all employees who smoke).

URAC-accredited companies will have to notify clients of material misrepresentations under a new standard proposed by URAC.  But first, some background:

URAC applicants that have relationships with both clients and consumers long have been confused by Core 21, which addresses communications practices for both.  (Remember, a "client" is the "business or individual that purchases services from the Organization," while a "consumer" is the "individual person who is the direct or indirect recipient of the services of the Organization.")   URAC is clearing up that confusion by limiting Core 21's applicability to consumers and creating a new standard for communications with clients.  That new standard would read:

The organization follows marketing and communication practices with clients that include: (--)
(a) Mechanisms to clearly and accurately communicate information about services inclusive of delegated activities to clients; (Wt = 3)
(b) A formal process of inter-departmental review of marketing materials before dissemination to clients to safeguard against misrepresentations about the organization’s services; and (Wt = 3)
(c) Monitoring of existing materials for accuracy; and (Wt = 3)
(d) Timely and complete correction notices to clients if any material misrepresentations are found. (Wt = M)

Subsections (a) and (c) are fundamentally unchanged from their Core 21 equivalents.  Subsection (b) is little more than the collapsing of two subsections of Core 21 ((b) and (c)) into one element.  The only substantively new element is (d), which, notably, is the only mandatory element of the new standard.  Most current URAC-accredited companies will need to add this provision to their communications policies, requiring "timely and complete correction notices" in the event of material misrepresentations.   

Core 21 provides:

The organization follows marketing and communication practices that include:
(a) Mechanisms to clearly and accurately communicate information about services to consumer and clients;
(b) Safeguards against misrepresentations about the organization’s services;
(c) A formal process of inter-departmental review of marketing materials before dissemination; and
(d) Monitoring of existing materials for accuracy.

While the intent of this standard is to assure that the information that applicants give to consumers about their services are accurate, it is not the kind of standard that the URAC reviewer can directly access compliance.  In other words, it is highly unlikely that the reviewer will be able to look at a piece of marketing material and determine that it is a misrepresentation about the organization’s services. 

The only example of this kind of direct assessment of compliance with the standard that I can recall had to do with the use of the URAC logo to signify accreditation status.  One thing about which URAC is quite clear is which organizations have received accreditation and for what programs.  If you use the logo in a way that suggests the scope of your accreditation is broader than it truly is, in that case, URAC is likely both to detect it and frown upon it.

Otherwise, however, the assessment of compliance with the standard is largely a process-oriented assessment.  The reviewer will focus his/her attention on mechanisms and processes.  Our baseline recommendations for compliance with the standard are:

• A policy and procedure that clearly describes the full array of mechanisms for communicating with consumers and clients, including those components of the processes that address assuring the accuracy of those communications;
• Documentation (meeting minutes for marketing materials review audit sheets) clearly demonstrating that the materials review process was interdepartmental;
• Documentation that all current marketing materials, whether print or electronic, have been subject to this interdepartmental review process.

It is important to note that even organizations that have no direct contact with consumers must comply with this standard, as it covers communications with clients, as well. 

It is also very important for applicants to understand that this standard does not apply only to newly-developed marketing materials.  Note that subsection (d) applies to existing materials.  Therefore, not only your policy and procedure, but also your execution of that policy, must include a documented periodic review of existing marketing materials for accuracy.