We Were Ready to Ask About Disability. We Weren't Ready for the Answer.
A few years ago, I was working with an ACO and a network of FQHCs on disability data collection.
We were making progress. The organizations understood why collecting disability status mattered. Some were already asking patients, and some were ready to move forward with implementation.
Then came the next question.
"Do you need any accommodations?"
Now, you would think that would be a natural follow-up. And it is. But that's also where we had to stop.
Because what happens when somebody says yes?
Not in theory. Not according to the policy sitting in a shared drive. I'm talking about when somebody is standing at your front desk or sitting in an exam room and tells you what they need.
Can you provide it? Does the person asking the question even know whether you can provide it? And if you can't do it right then, what happens next?
That's where things got interesting.
Some of the organizations already had accommodations in place because the law required them. Others had things in place simply because somebody recognized a need and did something about it.
And then there were things nobody had thought about.
Remember, we weren't working with one organization operating out of one building. We were working across a network of FQHCs. Different locations, different resources, different capabilities.
We realized we couldn't just roll out another question and assume everybody was prepared to handle the responses.
So we paused that part of the work. Each organization needed to figure out what it had, what it could put in place, and what needed more attention.
My work with the organizations ended at that point, so I can't tell you how they ultimately resolved it.
But I can tell you what that experience reinforced for me.
Sometimes the hardest part of implementing a requirement isn't the requirement itself. It's everything that comes after it.
Now Here Comes NCQA's HO 4
Fast-forward to 2026.
NCQA's Health Outcomes Accreditation standards now include HO 4, Access and Availability of Disability Accommodations.
And when I look at that standard, I think about those FQHCs.
Because this is exactly where organizations can underestimate the work.
It's one thing to say your organization provides accommodations. It's another to know what's available across your locations, whether employees know how to respond to requests, and what happens when someone needs something that isn't immediately available.
And let's be clear. These responsibilities didn't suddenly appear because NCQA added a standard. Healthcare organizations already had obligations under laws like the Americans with Disabilities Act and Section 504 of the Rehabilitation Act.
Accreditation adds another layer of scrutiny to how organizations demonstrate readiness.
The challenge is that the people responsible for collecting information aren't always the people who control the resources needed to respond.
Your front desk staff may receive the request. Your operations team may need to coordinate it. Your IT department may be involved if the issue concerns digital accessibility. Your compliance team needs to understand the requirements. And your quality team needs to know whether the process is working.
That's a lot of moving parts for what started as one additional question.
Somebody Has to Own What Happens Next
I've seen healthcare organizations put tremendous effort into getting ready for a survey.
Policies get updated. Training gets assigned. Documentation gets organized. Everybody is trying to make sure their piece is covered.
And I'm not dismissing any of that work. It's necessary.
But I want leaders to think about what happens after the policy is approved and the training is completed.
If a patient requests an accommodation tomorrow, can your organization explain what happens next?
Not just who receives the request. Who follows through?
If a particular location doesn't have the resources, is there a process to evaluate the request and determine an appropriate response?
Does someone know where the gaps are across your network?
And when something isn't working, who has the authority to address it?
These aren't questions that Quality or Compliance can answer alone.
This is where executive leadership must be involved, because some answers require decisions about staffing, resources, technology, workflows, and accountability.
You cannot assign responsibility for an outcome to a department that doesn't have the authority or resources to make it happen.
And you certainly cannot expect the person asking the question at the front desk to figure out the organization's accommodation strategy in real time.
Don't Confuse Asking With Being Ready
I want to be careful here because the takeaway is not that organizations should stop asking patients about their needs until everything is perfect.
That would miss the point.
Patients have rights, and organizations have existing responsibilities to provide appropriate accommodations and accessible services. Those responsibilities don't disappear because an organization hasn't finished developing a new process.
The point is that when we introduce a question, a policy, or a standard, we need to think through what implementation actually looks like.
What do we already have? What are we missing? What can we address now? What requires more coordination? And who is making those decisions?
In my experience, that's where some of the most important consulting work happens.
Not just interpreting the standard.
Not just preparing the documentation.
But helping organizations understand what the requirement means for the people expected to carry it out.
Before You Add Another Question
I still think about that ACO and those FQHCs.
We successfully moved forward with collecting disability-status information. But the next question required a different level of preparation.
There wasn't a neat ending to my part of the story. We reached a point where the organizations needed to take stock of their capabilities, and my engagement ended there.
But that's how organizational change sometimes works. You start doing one thing and uncover three other things that need attention.
The important part is recognizing the gap instead of pretending it doesn't exist.
So as healthcare organizations prepare for NCQA's updated Health Outcomes Accreditation standards, here's what I would ask leadership:
Are you preparing your organization to answer the survey questions, or are you preparing it to respond to the people those questions are supposed to serve?
There is a difference.
And your patients experience that difference long before a surveyor ever opens a file.
About Connected Consultants
Connected Consultants, LLC works with healthcare organizations to strengthen quality, compliance, accreditation readiness, and the operational processes needed to sustain improvement.
If your organization is working through the gap between what a standard requires and what your teams are prepared to deliver, let's talk.
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