Your Provider Directory May Be Telling Only Half the Story
NCQA HO 5: What health plans need to know about practitioner data, language services, and accessibility
Your provider directory may tell members which doctors are in network, where they practice, and whether they are accepting new patients. But does it tell them enough to determine whether they can actually receive care?
That is the question health plans need to be asking as they prepare for the 2026 NCQA Health Outcomes Accreditation standards.
A directory can be technically accurate and still leave members without the information they need to make an informed choice. Knowing a provider is available is not the same as knowing that provider can meet your needs.
And under NCQA HO 5, that distinction matters.
What changed in NCQA HO 5 for 2026?
HO 5, Practitioner Network and Care Site Responsiveness, focuses on whether an organization has the practitioner and care-site information necessary to assess and respond to its members' cultural, linguistic, and accessibility needs.
The 2026 standards apply to surveys on or after July 1, 2026.
For health plans, three elements deserve particular attention:
Element A: Practitioner and Site-Level Information — What information are you collecting?
Element B: Availability of Information on Practitioners and Care Sites — What information can members actually access?
Element C: Enhancing Network Responsiveness — How are you using that information to identify and address network gaps?
Elements D and E introduce requirements related to accessible medical equipment and care-site accessibility, but those elements apply to care delivery organizations, not health plans.
For health plans, the immediate challenge is connecting data collection, directory functionality, and network analysis.
These cannot operate as three disconnected activities.
What does HO 5 Element A require health plans to collect?
Element A addresses four categories of information:
Languages practitioners can use fluently when discussing medical care.
Practitioner race and ethnicity.
Language services available at care sites.
Auxiliary aids or services available at care sites.
The fourth category is new for 2026.
That addition matters because accessibility information is often treated as something to address after a member requests an accommodation.
But consider the member trying to select a provider in the first place.
If that member needs an assistive listening device or another communication-related aid, how are they supposed to know which care sites can support them?
If the information is not collected, the health plan cannot reliably communicate it.
And if the plan cannot communicate it, the member may be left to make calls, repeat their needs, or discover a barrier after scheduling an appointment.
Accessibility should not depend on how persistent a member is willing or able to be.
Collecting this information is one half of the picture. For what health plans must do once a member needs an accommodation during care, see our post on NCQA HO 4 for health plans.
There is also an important practitioner communication requirement. When collecting language, race, and ethnicity information, organizations must communicate that self-disclosure is voluntary and that disclosed information will not be used for discriminatory purposes.
A field in a credentialing system is not, by itself, evidence that this communication occurred. For Element A, meeting two to four applicable factors earns a Met score; meeting one earns Partially Met. For surveys scheduled July 1, 2026, through June 30, 2027, NCQA allows a detailed implementation plan, including a timeline, in place of the usual evidence for the new auxiliary-aids factor.
That is an opportunity to implement the requirement thoughtfully. It is not a reason to leave the work until the next survey cycle.
What does HO 5 Element B require health plans to make available?
This is where the conversation moves beyond data collection.
Element B is a new element that separates the availability of information from the act of collecting it.
Under the 2026 requirements, organizations must address five activities:
Publish practitioner languages in the provider directory.
Make practitioner race and ethnicity information available upon request.
Publish language services available at care sites in the directory.
Make information about care-site auxiliary aids or services available upon request.
Provide web-based search or filtering for at least one of those information categories.
Notice the distinction.
NCQA does not require every data point to appear publicly in the directory. Some information may be provided upon request.
But the process for obtaining that information must be established and supported by evidence. When information is available only upon request, members also need a clear way to know how to obtain it.
This is where I would challenge health plans to look beyond the minimum scoring threshold.
Can a member find the information without having to know the right question to ask?
For example, imagine a member who speaks a language other than English and needs to identify a practitioner who can communicate directly with them.
Does your directory help them narrow their search?
Or does it provide a phone number and leave the member to figure out the rest?
Now consider a member who needs a communication-related accommodation. Is there a clear path to learn which care sites offer the necessary support?
The answers tell you something important about how accessible your network really is.
Element B is scored Met when two to five applicable factors are met and Partially Met when one factor is met.
For surveys scheduled through June 30, 2027, a detailed implementation plan may be used for the auxiliary-aids information and web-search functionality factors.
That flexibility should help organizations build a more reliable process, not simply document an intention to do so.
What does HO 5 Element C require beyond the provider directory?
Collecting and publishing information are only part of the work.
Element C asks organizations to examine whether their networks can meet members' needs and to respond when gaps are identified.
At least once every three years, health plans must analyze:
Their network's capacity to meet members' language needs at the point of care.
Their network's capacity to provide culturally appropriate care.
These are critical scoring factors.
The organization must also develop a plan to address identified gaps and, when applicable, demonstrate action based on that plan.
This is where organizations can mistake having data for having insight.
A list of practitioners who speak Spanish does not automatically tell you whether Spanish-speaking members can access care in the locations where they live.
Likewise, collecting practitioner demographic information does not, on its own, demonstrate that the network is responsive to the population it serves.
You need to examine what the data means.
Where are members experiencing potential barriers?
Which needs are not adequately supported?
What can the organization change?
And once a gap is identified, what happened next?
Element C is scored Met when three or four applicable factors are met, subject to the critical-factor rules. If either critical analysis factor is not met, the score cannot exceed Partially Met. If neither is met, the score cannot exceed Not Met.
That makes the analysis itself essential, not optional background work.
Where are health plans most likely to get caught?
I would start with six questions.
1. Are your data collection systems aligned?
Practitioner language, race and ethnicity, care-site language services, and auxiliary aids may be housed in different systems or managed by different teams. Who is responsible for making sure the information is collected consistently?
2. Can you demonstrate the required practitioner communication?
Having a survey or credentialing form does not necessarily prove that practitioners were told disclosure is voluntary and nondiscriminatory.
3. Does your directory reflect the information you collect?
Data sitting in a spreadsheet or provider relations database does little for members if it never reaches the appropriate directory or information-request process.
4. Does your online directory support the required search functionality?
A directory that lists information is not necessarily a directory that allows members to search or filter by it.
5. Can members easily request information that is not published?
If your process depends on Member Services, staff need a reliable way to retrieve the information, and members need to know how to ask for it.
6. Is your network responsiveness analysis current and actionable?
An outdated analysis, or one that identifies gaps without documenting a response, creates both an accreditation risk and an operational concern.
None of these questions can be answered by the accreditation team alone. Provider relations, credentialing, network management, member services, digital teams, and quality leaders all have a role. That is why HO 5 readiness should be approached as a coordinated operational effort rather than a last-minute document collection exercise.
What should health plans do now?
Start with the member experience.
Open your provider directory and try to find a practitioner based on language needs. Then try to determine what accessibility-related support is available at a care site.
If the information is difficult to find, ask why.
Next, trace the information backward. Where does it originate? Who collects it? How is it updated? What happens when it is missing?
Then review the evidence supporting each applicable HO 5 factor. You should be able to connect the requirement to a process, the process to an accountable owner, and the owner to evidence that the work is happening.
Finally, examine your network analysis. If it identifies unmet needs, your response should be more than a statement that the organization will continue monitoring.
Monitoring a gap is not the same as addressing it.
The larger opportunity with HO 5 is to move from describing a network to understanding how well that network serves the people who rely on it.
A provider directory should do more than confirm that a practitioner exists within a network. It should help members make meaningful choices about their care.
And health plans should be able to demonstrate that the information behind those choices is being used to improve network responsiveness.
That is the work beyond the checklist.
Is your organization ready for NCQA HO 5?
At Connected Consultants, we help healthcare organizations translate accreditation requirements into operational processes, clear accountability, and survey-ready evidence.
If your team is working through the 2026 Health Outcomes standards, begin with our Health Outcomes Self-Assessment to identify potential readiness gaps.
For organizations addressing disability-related requirements across the standards, our Disability Accommodations Implementation Plan Checklist is another resource.
You can also schedule a complimentary 30-minute discovery call to discuss where your organization stands and what needs attention before your next survey.
The question is not simply whether your directory contains the required information. It is whether that information helps people access the care they need.
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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