Last updated: April 2026

Client identity anonymized per IHS confidentiality policy. Engagement details are representative of actual IHS work.

From Desktop Review Failure to URAC Health Plan with LTSS Accreditation: A 14-Month Turnaround

URAC Health Plan with Long-Term Services and Supports (LTSS) Accreditation validates that a health plan has the program infrastructure, person-centered care processes, and quality management systems to effectively serve members with long-term care needs. This case study describes how IHS guided a Medicaid managed care organization through a full accreditation turnaround — from a failed initial desktop review attempt to first-cycle URAC accreditation — in 14 months. Every engagement at IHS is principal-led by Thomas G. Goddard, JD, PhD, former Chief Operating Officer and General Counsel of URAC.

Client Profile

  • Organization type: Medicaid managed care organization (MCO)
  • Population served: Medicaid beneficiaries requiring home- and community-based services (HCBS), personal care, and institutional LTSS under a state managed care contract
  • Geography: Single-state operation, mid-Atlantic region
  • Members at engagement start: Approximately 18,000 LTSS-enrolled members
  • Accreditation target: URAC Health Plan with Long-Term Services and Supports Accreditation
  • State contract requirement: Accreditation required within 24 months of contract award; state accepted URAC or NCQA
  • IHS engagement start: Organization engaged IHS following an unsuccessful initial attempt at URAC desktop review — the application was returned with 27 open findings across core Health Plan and LTSS module standards

The Challenge

The organization had pursued URAC accreditation independently during its first year under the state contract, relying on internal compliance staff who had experience with state Medicaid audits but no prior URAC accreditation experience. The initial application was submitted on an accelerated timeline to meet a self-imposed internal deadline.

URAC's desktop review returned 27 findings:

  • 11 findings in LTSS module standards — including deficiencies in the functional assessment tool (missing medication review component and documentation of available community resources), care plan templates that did not meet URAC's person-centered specificity requirements, and an absent LTSS-specific quality management program
  • 9 findings in core Quality Management standards — the QM program description referenced LTSS population-level outcomes in general terms but did not include LTSS-specific measures, data sources, or improvement targets
  • 4 findings in Delegation Oversight — the organization delegated personal care authorization and community provider management to a subcontractor but lacked a formal delegation agreement with URAC-required oversight provisions, monitoring schedules, or corrective action protocols
  • 3 findings in Consumer Protection — member notice templates for LTSS-related adverse determinations did not include required appeal rights language specific to LTSS services

The organization had 90 days to remediate and resubmit before the application would be closed. It engaged IHS at day 12 of that window.

IHS Approach

Week 1–2: Rapid Gap Triage and Remediation Sequencing

Thomas G. Goddard, JD, PhD conducted a full review of the 27 URAC findings alongside the organization's existing policies, procedures, delegation agreements, and operational documentation. Findings were categorized into three tracks:

  • Track A — Document remediation: Findings that required revisions to existing documents (care plan templates, QM program description, member notices). These could be resolved within the 90-day window with focused drafting effort.
  • Track B — Operational build with documentation: Findings that required both new operational processes and new documentation — specifically the LTSS functional assessment tool revision and the delegation oversight framework. These required both policy development and operational implementation before URAC's next desktop review.
  • Track C — Evidence gap: Findings that required documented evidence of consistent implementation over time — not just revised policies. The LTSS quality management program was in this category; URAC would need to see QM committee minutes, data dashboards, and at least one improvement cycle documented.

The Track C finding was the most consequential. URAC's standards require operational evidence, not just written programs. The organization had 90 days to resubmit documentation — but Track C evidence could not be manufactured in 90 days. IHS advised a deliberate strategy: resubmit Track A and B findings within the 90-day window to maintain the application's active status, and present a documented LTSS QM program launch plan with an explicit timeline for Track C evidence production. This aligned with URAC's expectation that organizations demonstrate a credible path to compliance, not just a completed document set.

Weeks 2–6: Document Remediation (Track A and B)

IHS led the development of revised and new documentation across all 27 findings:

  • LTSS Functional Assessment Tool: Revised to incorporate a structured medication review component, a community resources section documenting available HCBS options by member geography, and a member-input documentation field aligned to URAC's LTSS 4 requirements
  • Person-Centered Care Plan Template: Rebuilt from the ground up to include all LTSS 5 required elements — member goals in the member's own language, caregiver and support network participation documentation, identified care coordination needs, scheduled reassessment dates, and an ongoing care plan management log
  • LTSS Quality Management Program Description: Developed a standalone LTSS QM program document with defined population scope, LTSS-specific measures (including community integration rates, unplanned institutionalization rates, and care plan completion timeliness), data sources, committee structure, and an improvement cycle methodology
  • Delegation Agreement — LTSS Subcontractor: Drafted a compliant delegation agreement for the personal care authorization and community provider management functions, including URAC-required oversight provisions, a quarterly monitoring schedule, a corrective action protocol, and an annual delegation audit framework
  • Member Notice Templates: Revised adverse determination and appeal notices for LTSS-related decisions to include required appeal rights language, timeframes, and state fair hearing references

Weeks 6–10: Operational Implementation and Evidence Building (Track C)

Simultaneously with document remediation, IHS worked with the organization's operations and compliance teams to implement the revised LTSS QM program operationally:

  • Stood up a dedicated LTSS QM subcommittee with defined membership, meeting cadence, and charter
  • Implemented LTSS-specific data dashboards tracking the three primary measures defined in the new QM program description
  • Conducted the first formal LTSS QM committee meeting with documented minutes, data presentation, and an identified improvement opportunity with an assigned action owner and target date
  • Drafted a 6-month LTSS QM implementation roadmap as an exhibit to the Track C resubmission narrative

Day 88: Resubmission

IHS prepared and quality-reviewed the complete resubmission package — revised documents, a finding-by-finding response matrix, and a Track C narrative with supporting evidence and the 6-month QM roadmap. The package was submitted to URAC on day 88 of the 90-day window.

Months 4–9: Continued Operational Track Record

Following resubmission, the organization continued building operational evidence under IHS's guidance. Over the next five months, the LTSS QM program produced two documented improvement cycles, the functional assessment tool was used across 100% of new LTSS assessments, and care plan completion rates were tracked and reported at each monthly QM committee meeting. The delegation subcontractor completed its first quarterly monitoring review with documented findings and a corrective action plan for two identified gaps.

Month 10: URAC Interview Preparation

URAC notified the organization that the desktop review was cleared and scheduled structured interviews. IHS conducted three mock interview sessions with the organization's LTSS program director, QM director, and compliance officer — focusing on LTSS module standards where surveyors most commonly probe for evidence of actual operational practice rather than policy familiarity. Common questions addressed: how person-centered goals are documented when members are non-verbal or cognitively impaired; how care coordinators identify and address unmet community resource needs; and how the LTSS QM committee connects data findings to specific operational improvements.

Month 12: Survey

URAC conducted a two-day virtual survey. Surveyors reviewed case files from 20 LTSS-enrolled members, interviewed five staff members across care coordination, QM, and compliance functions, and reviewed a sample of delegation monitoring reports from the personal care subcontractor. IHS was available throughout the survey period for real-time support and post-session debriefs with organizational leadership.

Month 14: Accreditation Decision

URAC's Accreditation Committee awarded full URAC Health Plan with Long-Term Services and Supports Accreditation. No post-survey RFI was issued. The organization met its state contract accreditation requirement with 10 months to spare before the state deadline.

Outcomes

  • 27 URAC findings fully resolved across LTSS module, Quality Management, Delegation Oversight, and Consumer Protection standards
  • First-cycle accreditation awarded — no post-survey RFI issued
  • 14 months from IHS engagement to accreditation decision
  • State contract deadline met with significant margin
  • LTSS QM infrastructure built to support ongoing accreditation maintenance and state reporting requirements simultaneously
  • Delegation oversight framework extended beyond URAC requirements to cover all delegated LTSS functions, reducing state audit exposure

Key Lessons

Operational evidence cannot be created retroactively. The most common reason URAC accreditation timelines extend is that organizations draft compliant policies but cannot demonstrate consistent operational implementation. Building the QM program, running it through at least one improvement cycle, and documenting the results takes months — policies alone are not sufficient evidence.

LTSS delegation oversight is consistently underestimated. Organizations that delegate LTSS functions to community providers or subcontractors frequently overlook the URAC requirements for the oversight structure — including formal delegation agreements, monitoring schedules, and corrective action protocols. A URAC-compliant delegation agreement looks different from a standard vendor contract.

Person-centered care plans require more than a template revision. URAC's LTSS 5 standards assess whether the care planning process is genuinely member-driven — not just whether the template has the right fields. Surveyors look for evidence in individual case files: member goal language that reflects the member's own voice, documented participation by caregivers, and records of ongoing care plan updates based on changing member needs. Template compliance is necessary but not sufficient.

Starting with an experienced consultant reduces total elapsed time. The organization's independent attempt added approximately 6 months to the total timeline — the time spent developing and submitting an application that failed desktop review, receiving findings, and engaging IHS. Organizations that engage IHS at the outset of accreditation planning — rather than after a failed attempt — consistently achieve accreditation faster and with fewer revision cycles.

About IHS

Integral Healthcare Solutions provides accreditation consulting, compliance services, and healthcare program development for health plans, managed care organizations, specialty pharmacies, and healthcare service organizations. Every IHS engagement is principal-led by Thomas G. Goddard, JD, PhD, former Chief Operating Officer and General Counsel of URAC. IHS has guided organizations through URAC accreditation across health plan, pharmacy, utilization management, and specialty accreditation programs.

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