URAC Core 15-18 -- Delegation

Delegation occurs any time (with but one exception) your organization is required to do something by a URAC standard and you have somebody else do it. The only exception is provider contracting: if you have someone else (like an IPA or a PPO) contract with the providers in your network, you haven't delegated provider contracting.
Simple, right?

One might think so, but look at the rules of delegation from URAC's Core standards 15-18:

CORE - 15 - Delegation Review Criteria
The organization establishes and implements criteria and processes for an assessment prior to the delegation of functions.

CORE - 16 - Delegation Review
Prior to delegating functions to another entity, the organization: (N/A)(a) Conducts a review of the potential contractor’s policies and procedures and capacity to perform delegated functions; and (b) Outlines and follows criteria and processes for approving contractors.

CORE - 17 - Delegation Contracts
The organization enters into written agreements with contractors that:
(a) Specify those responsibilities delegated to the contractor and those retained by the organization;
(b) Require that services be performed in accordance with the organization's requirements and URAC standards;
(c) Require notification to the organization of any material change in the contractor’s performance of delegated functions;
(d) Specify that the organization may conduct surveys of the contractor, as needed;
(e) Require that the contractor submit periodic reports to the organization regarding the performance of its delegated responsibilities;
(f) Specify recourse and/or sanctions if the contractor does not make corrections to identified problems within a specified period;
(g) Specify the circumstances under which activities may be further delegated by the contractor, including any requirements for obtaining permission from the organization before any further delegation; and
(h) Specify that, if the contractor further delegates organizational functions, those functions shall be subject to the terms of the written agreement between the contractor and the organization and in accordance with URAC standards.

CORE - 18 - Delegation Oversight
The organization implements an oversight mechanism for delegated functions that includes:
(a) A periodic review (no less than annually) of the contractor’s policies and procedures and documentation of quality activities for related delegated functions;
(b) A process to verify (no less than annually) the contractor’s compliance with contractual requirements and policies and procedures; and
(c) A mechanism to monitor financial incentives to ensure that quality of care or service is not compromised.

Yikes. A lot going on there. How can I make it simpler?

Delegate to a URAC accredited company. Why?, because Core 15, 16, and 18 vanish when you do so, and you are left with only Core 17's requirements. Getting rid of 3 of the 4 applicable standards by contracting only with URAC-accredited companies is a sure-fire way to reduce the burden of delegation oversight. All that's left is that you execute a contract with the contractor that complies with Core 17, and you've complied with URAC's standards.

But what if you cannot avoid contracting with non-URAC-accredited company?

Take a deep breath, and learn the other three standards. Here's what that entails, in summary:

Core 15 -- figure out, before you undertake a delegation, how you are going to discern those oganizations you'll ask to do things for you from those you won't. Are there quality criteria, conditions of contracting, etc.? IF so, write them down.
Core 16 -- Then, using the criteria you've developed for Core 15, and after reviewing the P&Ps of the prospective contractor, and after making sure the contractor has adequate qualified staff to do what they say they'll do, document the process of approving the contractor to do the delegated function for you.
Core 18 -- Finally set up a system under which, every year, you review the contractor's P&Ps and performance under the delegation agreement, and that you make sure that the contractor doesn't have any financial incentives that could be bad for your consumers.

Required documents
What documents do you need? One P&P on delegation that covers all of the above, sample reports of your audit process, and a template of your delegation agreement. During the onsite review, have one "delegation binder" for each contractor, and make sure the binder contains the delegation agreement with the contractor, any periodic reports the contractor submits to you, the P&Ps you've reviewed, and any audit or survey reports for that contractor. If the contractor is URAC-accredited, include some evidence (copy of the URAC accreditation certificate or a screen-shot of the URAC web site listing the contractor as accredited).

More on the delegation agreement
What about the agreement with the contractor? Any tricks there? You bet! Here are the most common mistakes:

1. Lots of applicants fail to appreciate the importance of subsection (b), which requires that the delegation agreement specifically require the contractor to comply with URAC standards, not just yours.
2. Many have missed subsection (c)'s requirement that the contact place an affirmative obligation on the contractor to let you know if anything happens that threatens its ability to do what you've asked it to do.
3. Many applicants have not been rigorous about subsections (g) and (h), especially (h). The trick here is to make sure that the agreement imposes URAC standards on the subdelegates of your contractors, and that it specify the conditions under which it may delegate (such as getting your written permission).