URAC Core 31 -- Quality Management Program Requirements

Core 32, which outlines the requirements for the quality management program, is quite straightforward and, on its face, easy to document:

The organization has a written description for its quality management program that: (Primary)
(a) Is approved by the organization’s governing body; (Secondary)
(b) Defines the scope, objectives, activities, and structure of the quality management program; (Secondary)
(c) Is reviewed and updated by the Quality Management Committee at least annually; (Secondary)
(d) Defines the roles and responsibilities of the Quality Management Committee; and (Secondary)
(e) Designates a member of senior management with the authority and responsibility for the overall operation of the quality management program and who serves on the Quality Management Committee. (Secondary)

The Program Guide says that all you need do at the Application stage is submit a "Program description and plan or P&Ps addressing QM oversight of the program," and your documentation worries are over.

And, for some reviewers, that may be so. However, you can save yourself the risk of a dispute over the adequacy of that documentation, and take some of the work out of the onsite review process, if you go a bit farther in demonstrating compliance with subsections (a) and (c). These subsections contemplate review and approval by specific panels, with (a) focusing on the governing body and (c) looking at the QM Committee.

At some point in the process, either during the desktop review or the onsite review, the reviewer will need to see documentation independent of the QM Program Description that the governing body has approved the QM Program Description and that the QM Committee, within the past year, has reviewed and approved it.

I recommend that you do this up front, at the Application stage of the process. This should be easy -- submit committee minutes demonstrating such committee approval by both of these panels or submit signed, dated attestations from the chairs of these to bodies indicating that their committees have, as required, approved the program document, and when each committee did so.

While I usually think the Program Guide provides the best idea of what documentation will suffice for a particular standard, this is one situation in which I think it's best to go a bit farther.