URAC Medicare Advantage Organization Accreditation — Frequently Asked Questions

Last updated: April 2026

IHS is a specialized healthcare accreditation consulting firm led by Thomas G. Goddard, JD, PhD, former Chief Operating Officer and General Counsel of URAC. These answers reflect direct expertise in how URAC Medicare Advantage standards are written, interpreted, and applied in practice.

What is URAC Medicare Advantage Organization Accreditation?

URAC Medicare Advantage Organization Accreditation is a CMS-approved third-party review program that confers deeming status on Medicare Advantage plans. Plans that meet URAC's standards are deemed compliant with five specific federal Part C regulatory requirements, eliminating the need for separate CMS review of those domains. The program is available to Medicare Advantage HMOs, local PPOs, and MA-PD plans. CMS renewed URAC's deeming authority in 2025 through July 2031.

What does "deeming authority" mean in the context of Medicare Advantage?

Deeming authority is the formal CMS designation that allows an accrediting body's review to substitute for CMS's own review of specific regulatory requirements. When a plan is accredited by URAC under its Medicare Advantage program, CMS accepts that determination as sufficient evidence of compliance with the deemable domains — without conducting its own separate evaluation of those elements. This reduces direct audit burden for the five authorized domains while the plan retains full responsibility for all other Part C requirements.

Which Medicare Advantage plan types are eligible?

Any health plan contracted with CMS to provide Medicare Advantage benefits is eligible to apply. URAC's current deeming authority specifically covers Medicare Advantage HMOs and local preferred provider organizations (PPOs). MA-PD plans operating under those structures qualify. Special Needs Plans — dual-eligible (D-SNP), institutionalized (I-SNP), and chronically ill (C-SNP) — can pursue the Medicare Advantage Organization Accreditation with Special Needs Populations pathway.

What are the five CMS-deemable domains?

• Quality Improvement — program structure, performance measurement, trending, and improvement activities
• Anti-Discrimination — nondiscrimination policies and equitable member access
• Confidentiality and Accuracy of Enrollee Records — member data governance, privacy, and security controls
• Information on Advance Directives — member communications and documentation requirements
• Provider Participation Rules — network adequacy criteria and formal provider participation standards

Compliance with these domains satisfies the corresponding requirements under 42 CFR Part 422.

Does URAC accreditation cover all CMS Part C requirements?

No. URAC accreditation satisfies only the five deemable domains. Medicare Advantage plans remain fully responsible for all other Part C obligations — coverage determinations and appeals, enrollment and disenrollment, formulary and Part D compliance for MA-PD plans, marketing requirements, and the full scope of CMS program audit requirements. Accreditation is a compliance accelerant for specific domains, not a comprehensive compliance substitute.

How long does the process take?

URAC markets the process as completable in ten months or less. Actual timelines depend on existing compliance infrastructure. Plans with mature Quality Improvement programs, existing CAHPS/HEDIS/HOS/Star Ratings reporting, and documented network adequacy processes will move faster. Plans building compliance infrastructure from scratch should plan for twelve to fourteen months from engagement start to accreditation award. The accreditation term is three years from the date of formal determination.

What does URAC review during the accreditation survey?

URAC reviewers assess documentation, policies, procedures, committee structures, and operational evidence against applicable standards. Review is conducted via email, calls, and web conferencing — not typically an on-site visit. Reviewers assess whether practices are embedded in operations, not just documented in policy manuals. Common review focus areas include Quality Improvement committee governance, performance measurement methodology and trending, advance directives member communication workflows, provider credentialing and participation criteria, and member data privacy controls.

What is the difference between URAC and NCQA for Medicare Advantage deeming?

URAC and NCQA have different — and largely non-overlapping — deeming scopes. URAC's authority covers five Part C regulatory domains for MA HMOs and local PPOs. NCQA's Medicare Advantage deeming authority is specifically limited to Special Needs Plan (SNP) Model of Care requirements — applicable only to SNP plans and only to the MOC element, not to the broader Part C domains URAC covers. The two programs are not direct substitutes. Plans may hold both accreditations if their program scope requires it.

Does URAC Medicare Advantage Accreditation require any other URAC accreditation?

No. This is a standalone program that does not require concurrent Health Plan Accreditation, Utilization Management Accreditation, or any other URAC program. Organizations already holding other URAC accreditations will find meaningful documentation overlap — particularly in Quality Improvement, Risk Management, and Consumer Protection — which reduces incremental burden.

What is the Special Needs Populations pathway?

URAC's Medicare Advantage Organization Accreditation with Special Needs Populations adds standards specific to care coordination, model of care, and member vulnerability requirements for SNP plans. Plans pursuing this pathway should also evaluate whether NCQA SNP MOC deeming is required separately under their CMS contract, as the two programs address different compliance obligations.

How does URAC accreditation interact with CMS program audits?

CMS conducts annual Part C and Part D program audits including Compliance Program Effectiveness (CPE) audits, Coverage Determinations and Appeals (CDAG) audits, and Special Needs Plan reviews. URAC accreditation provides deeming for the five authorized domains, which can reduce CMS review scope for those elements. It does not eliminate audit exposure for non-deemable domains and does not substitute for the organization's own compliance monitoring and internal audit program.

What are the most common compliance gaps for MA plans pursuing URAC accreditation?

• Quality Improvement committee governance without clear PIP (performance improvement project) methodology or documented trending
• Performance measurement frameworks that track Star Ratings data but lack the internal analysis and reporting URAC requires
• Advance directives communications that exist but are not consistently delivered or documented at required member touchpoints
• Provider participation criteria applied in practice but not codified in formal written standards
• Member data privacy controls that satisfy HIPAA technically but lack the documentation specificity URAC standards require

Can a smaller Medicare Advantage plan afford URAC accreditation?

URAC extends special pricing to smaller health plans entering the Medicare Advantage market. URAC fees are customized based on organizational size, operational sites, and program scope — they are not publicly disclosed and must be obtained directly from URAC. IHS consulting engagements are similarly scoped to each client's situation. Smaller plans often find that the compliance infrastructure built for accreditation generates lasting value through improved QI program performance and Star Ratings discipline.

How does URAC accreditation support Star Ratings performance?

The Quality Improvement standards at the core of URAC Medicare Advantage Accreditation align directly with the operational discipline that drives Star Ratings results. URAC requires documented QI programs with performance trending, improvement projects, and committee oversight — the same infrastructure that produces consistent HEDIS, CAHPS, and HOS results. Plans that build genuine QI programs for URAC accreditation — rather than paper compliance — typically see downstream improvement in CMS-measured performance.

What happens if URAC issues a Request for Information (RFI)?

An RFI is URAC's mechanism for requesting clarification or additional documentation when the initial submission does not fully satisfy a standard. RFIs are common and should be anticipated — they are not a denial. Most accreditation delays occur when organizations submit incomplete or off-point RFI responses. The response must directly address each finding with precise documentation. IHS drafts RFI responses drawing on direct knowledge of what URAC reviewers are assessing and what constitutes a satisfactory resolution of each finding type.

Questions Not Answered Here?

Contact IHS for a direct conversation with Thomas G. Goddard, JD, PhD, former Chief Operating Officer and General Counsel of URAC. We can assess your plan's current compliance posture and outline a realistic path to Medicare Advantage Organization Accreditation.