NCQA HO 4 for Health Plans: What Elements C and D Require
In our last HO 4 post, we talked about the human side: what happens after someone tells you they need an accommodation. This post is the practical side for health plans: which HO 4 elements apply to you, what each one requires, and what evidence a surveyor will ask for.
Which HO 4 elements apply to health plans?
HO 4, Access and Availability of Disability Accommodations, is a new standard with four elements. Two of them are for care delivery organizations only. If you are a health plan, your work sits in Elements C and D.
Element A, arranging accommodations before visits: care delivery organizations only.
Element B, sharing accommodation data and training care teams: care delivery organizations only.
Element C, training practitioners on accommodations: health plans.
Element D, accessible digital content: health plans and care delivery organizations.
Element C: What training do health plans have to offer?
Health plans must offer training to practitioners on two things: using physical accommodations during care, and using auxiliary aids and services during care. That includes members' own equipment and devices. Meet either factor and the element is Met. There is no Partially Met, so this one is all or nothing.
The standard leaves training frequency to you, and it lets plans collaborate with other organizations in their service area to offer common training. Topics NCQA points to include:
Anticipating accommodations for specific exams or procedures.
Using equipment such as height-adjustable exam tables and transfer boards, or providing a low-stimulation environment.
Using auxiliary aids such as sign language interpreters, picture boards, real-time captioning (CART) and portable hearing loops.
Caring for members who use communication aids to be understood.
Involving a member's designated support person.
Respectful, member-focused communication.
Evidence NCQA accepts includes training slides or curricula, a training plan, attendance logs or dashboards, meeting minutes, user guides sent to practitioners, and certificates of completion.
Element D: What does accessible digital content mean for a health plan?
Digital content means your website, mobile app, member portal, downloadable PDFs and any kiosks or tablets. The requirement focuses on vital information. For a health plan, that includes:
Eligibility, benefits and coverage information, such as welcome packets, benefit summaries and explanations of benefits.
Notices that deny, reduce, change or end services or benefits.
Information about the right to file a grievance or appeal.
Notices that a practitioner is leaving the network.
There are six factors. Meet three or more and the element is Met; meet two and it is Partially Met.
Vital information in plain, easy-to-understand language.
Vital information in screen-reader-accessible formats.
Speech-to-text (captions or transcripts) for audio and video.
Large-text functionality.
Accessibility features that are easy to find.
A process to test usability with the people the content is meant for.
One useful detail: you can hire an outside vendor to do the usability testing in factor 6. NCQA reviews the vendor's documentation and does not treat that relationship as delegation.
What changes after June 30, 2027?
For surveys scheduled July 1, 2026 through June 30, 2027, health plans may submit a detailed implementation plan, with a timeline, in place of evidence for Elements C and D. After that window closes, surveyors expect proof: training that was actually offered, and digital content that actually meets the factors.
If your survey falls after June 2027, your implementation plan is really a build schedule. The training has to be designed, delivered and documented before your look-back period ends.
Where health plans are likely to lose points
Training the wrong audience. Element C is about practitioners. Internal staff training on its own doesn't meet it.
A memo instead of a training. A policy sent to the network, with no curriculum and no record of who received it, is hard to defend.
Scanned PDFs. EOBs, denial letters and welcome packets saved as image-only PDFs can't be read by a screen reader.
Buried accessibility settings. A large-text option three menus deep doesn't count as easy to find.
No testing with real users. Factor 6 asks how you tested with the intended audience, not whether a tool passed an automated scan.
No owner. Digital content sits with marketing, IT, compliance and member services. Someone has to own the whole thing.
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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