April 23, 2026

QUESTION:
Our hospital performs payor enrollment/delegated credentialing on behalf of healthcare insurers.  We were recently told during an insurer audit of our credentialing process that we have to include a question about race, ethnicity, and language on our application forms.  Is that correct?

ANSWER FROM HORTYSPRINGER ATTORNEY CHARLES CHULACK:
Yes.  The standards for the NCQA, one of the primary accreditation entities for insurers, that went into effect on July 1, 2025 included a new factor for practitioner applications.  The factor required the “application [to] include fields to enter race, ethnicity and language, and a statement that the organization does not discriminate or base credentialing decisions on an applicant’s race, ethnicity or language, and that providing the information is optional.”

In our work with clients, we understand that the NCQA and insurers are requiring these questions to be included on initial and recredentialing applications. Furthermore, the NCQA issued an FAQ on May 5, 2025 indicating that “[t]he requirement is for the application to have separate fields to enter responses for each of these three data points (race, ethnicity, and language).  However, it would be acceptable to group these into one question if the application prompts the user to provide separate responses for race, ethnicity and language.”

For more information about payor enrollment and delegated credentialing, join Horty, Springer & Mattern partners Charles Chulack and Lauren Massucci for the webinar The Nuts and Bolts of Delegated Credentialing – A “How To” for Organizational Providers on Implementing and Improving a Payor Enrollment Program, which will be available on our website on April 28, 2026.

If you have a quick question about this, e-mail info@hortyspringer.com.