NCQA HO 2 Disability Data: What Health Plans Must Collect and When It Counts
For years, many organizations captured disability with a single yes/no field, if they captured it at all. The 2026 Health Outcomes standards end that. HO 2 now asks how you collect disability status, what response options you offer, how you record a non-answer, and whether people with disabilities can actually complete your questions. Here is what health plans need to know.
What's new about disability in HO 2?
Element D, Collection of Data on Disability Status, is new and applies to health plans and care delivery organizations.
Element E, Collection of Data on Disability-Related Accommodations, is new and applies to care delivery organizations only.
Elements G, H, and I now include disability. You must show evidence of collection (G), store and retrieve the data in your systems (H), and protect it with privacy policies (I).
What does HO 2 Element D require?
Element D has four factors. Meet two or more, and it is Met; meet one, and it is Partially Met.
Accessible collection. Your methods must work for people with intellectual, visual, and auditory disabilities. This is a critical factor: if you miss it, the element cannot score higher than Partially Met.
Disability function. A documented process to collect direct data on functional difficulty from all members.
Disability identity. A documented process to collect direct data on whether members identify as having a disability, and how they describe it.
HEDIS reporting. Report the HEDIS measure Disability Description of Membership, separately for commercial, Medicaid and Medicare.
Answering is voluntary for members, but you are expected to ask, through as many channels as you have.
Function and identity are two different questions
Function asks about difficulty with everyday activities. Required response options cover hearing; seeing, even with glasses; concentrating, remembering or making decisions; walking or climbing stairs; dressing or bathing; doing errands alone; communicating; other difficulties; "don't know"; and "choose not to disclose at this time." NCQA's examples include the American Community Survey and Washington Group yes/no questions and a check-all-that-apply format from the DEMo initiative.
Identity asks how a person sees themselves. The required format is two questions: whether the member identifies as having a disability, and how they would describe it, from a set list of categories.
Someone can have functional difficulty and not identify as disabled. Someone else can identify as disabled and have no difficulty today because the right supports are in place. That's why NCQA asks for both.
The detail most teams miss: recording a non-answer
Your system has to tell three situations apart:
The member answered and has no difficulty or does not identify as having a disability.
The member chose not to disclose, or said they don't know.
You asked and haven't received an answer yet.
You also need a defined process for following up when you asked and got no answer. A single yes/no field can't do any of this.
What goes in your documented process?
NCQA calls this a direct data collection framework. It should spell out:
Which members you will collect from.
When and where collection happens.
How it happens, who does it, and how you make it accessible.
The exact questions, plus a script for staff who ask verbally.
How you follow up when a question goes unanswered.
You can use more detailed response options than NCQA requires, as long as your process explains how they map back to the required ones.
When does disability data start counting?
Element D is not applicable for surveys before June 30, 2027. Evidence of collecting disability function and identity (Element G, factors 4 and 5) is also not applicable for surveys from July 1, 2026 through June 30, 2027.
That doesn't mean you can wait. Your first scored survey will look for a documented process, accessible collection methods, systems that can store the answers, and privacy policies that cover them. That is several quarters of work. Use the relief year to build it and test it with members.
Where organizations get caught
One yes/no field. It can't capture function and identity separately, or tell "choose not to disclose" from "not asked yet."
No staff script. Staff who ask verbally need respectful, consistent wording.
Inaccessible forms. A collection form a screen reader can't read fails the critical factor.
Free-text notes. Answers buried in notes can't be retrieved, stratified or reported.
Not sure where you stand?
Run the 10-question check in our 2026 Health Outcomes Readiness Snapshot, then bring your answers to a free 30-minute readiness review. You'll leave with your top three priorities.
About the author. Dr. Deann Johnson, MHA/MBA, CPHQ, CHC, is the founder and principal consultant of Connected Consultants LLC, a healthcare consulting firm specializing in NCQA accreditation readiness, quality improvement and organizational development.
Based on NCQA, 2026 Standards and Guidelines for Health Outcomes and Community-Focused Care Accreditations (effective for surveys on or after July 1, 2026). This summary is for planning purposes only and is not affiliated with or endorsed by NCQA.
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