URAC Core 21 -- Communications Practices

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.