Maintaining standards of care
The Quality Management (QM) Program monitors and objectively evaluates the quality and effectiveness of care for our members.
Quality Management Program
The Independence Quality Management (QM) Program is organized around a vision of supporting optimal health outcomes and satisfaction with care for our members, as well as meeting all applicable regulatory and accreditation requirements.
- Assess and improve the safety of medical and behavioral health care and services provided to members
- Evaluate the sufficiency of the plan networks for members to access qualified providers for timely and appropriate care
- Ensure evidence-based, effective care is provided to members for their medical and behavior health conditions
- Promote efficient care and reduce health care waste through facilitating communication, continuity, and coordination of care among providers and supporting a focus on prevention and appropriate level of service
- Promote health equity among diverse populations by identifying and addressing social needs, including access to care that fits cultural and linguistic preferences
- Assess and address the satisfaction of members with their health care plan and services to support patient-centered system improvements
The QM Program supports an ongoing comprehensive program of continuous quality improvement throughout the organization, monitoring the performance of our internal functional areas as well as the quality of care our members receive in our network. The program is based on comprehensive, integrated, and systematic processes driven by quality improvement principles and customer feedback. The QM team uses standardized measures of care and service quality to assess Plan performance and the performance of our network providers against our standards and goals. To identify and prioritize opportunities to improve clinical care and service, member safety, and member experience, the team supports the analysis of process and outcome measures. The QM Program convenes service and clinical quality committees monthly to assess performance, set goals, and develop performance improvement plans.
The QM Program implements the Member Safety Program, facilitates the organizational Population Health Management Strategy, and assesses the adequacy of the network. It also ensures delegation oversight, credentialing compliance, and clinical services compliance. Finally, it implements policies and procedures to ensure plan compliance with established standards of practice, NCQA accreditation standards and CMS, Pennsylvania, New Jersey, and other regulatory requirements.
Member Safety Program:
- Reviews and addresses member adverse occurrences, complaints, and concerns about the health care they have received*;
- Reviews claims data to identify potential safety and care quality issues, including medical and medication errors, for providers;
- Educates network providers about effective safety practices and resources and Independence’s standards of care and access for our members;
- Notifies network providers about gaps in members’ health care, errors, complaints, and adverse occurrences;
- Coordinates with other internal departments to identify providers, patterns, and practices that could pose member safety and quality of care issues;
- Ensures provider compliance with Plan quality standards through appropriate measurement, audit, and hearing processes;
- Oversees processes for provider recognition in the provider directory for high-quality care, e.g., the Blue Distinction Center program;
- Produces quality review reports to inform the Plan contracting process with providers;
- Works with regional coalitions to bring providers together through collaborative patient safety initiatives and information sharing.
Population Health Management Strategy:
- Monitors the health status and needs of our members, including identifying geographic and demographic differences in health factors;
- Monitors and evaluates the care our members receive;
- Monitors and facilitates care coordination capacity among providers and practitioners;
- Synthesizes the various components of population health management into a cohesive organizational strategy and coordinates across the organization to drive progress toward the Triple Aim;
- Evaluates the effectiveness of Plan programs and initiatives designed to improve the health outcomes, the value of care, and the experiences of our members, e.g. our preventive health outreach and condition management programs.
- Evaluates the sufficiency of the plan networks for members to access qualified providers for timely and appropriate care;
- Monitors the capacity of the network to offer access to high volume and high need specialties and linguistically and culturally appropriate care;
- Verifies and monitors the credentials and good standing of all network providers.
- Recognizes high performing providers and identifies providers with unsafe practices or non-compliance for education and corrective action plans;
- Assesses and supports initiatives around change to level of care and scope of practice changes to coverage;
- Assesses and addresses the satisfaction of members with their health plan and care.
Additional information about our Quality Management Program, including a description of our yearly plan and a report on progress, is available to members and providers, upon request. Provider requests, call 1-800-ASK-BLUE. Additional information about QM activities can also be found on our Provider News Center.
Members may request information about the QM Program by calling the Member Services number listed on the back of the ID card.
*Members who have concerns or complaints about the quality of care or service they received from a provider may call the Member Services number listed on back of the ID card and request to file a quality-of-care complaint.
NCQA is an independent, not-for-profit organization dedicated to assessing and reporting on the quality of managed care plans, managed behavioral healthcare organizations, preferred provider organizations, new health plans, physician organizations, credentials verification organizations, disease management programs and other health-related programs.
NCQA Health Plan Accreditation evaluates how well a health plan manages all parts of its delivery system— physicians, hospitals, other providers and administrative services—in order to continuously improve the quality of care and services provided to its members. NCQA sends a team of trained health care experts, including physicians, to conduct a rigorous on-site survey of the health plan. NCQA uses information from health plan records, consumer surveys, interviews with plan staff and performance on selected HEDIS® measures.
Learn more about Independence’s accreditation statuses and other health care quality information on NCQA’s website at https://www.ncqa.org.
Access and availability standards
Independence Blue Cross (Independence) is committed to maintaining an adequate network of primary and specialty care providers to meet the needs and preferences of its members. To ensure access and availability to care, Independence has established standards for the number and distribution of providers in our networks as well as timeliness of care. Each year, Independence assesses how effectively our networks ensure appropriate access and availability of care to our members.
In order to meet the needs of our members, participating providers should adhere to the following standards:
In the event of an emergency or immediate need, members should call 911 or go to the nearest emergency room. For non-life-threatening urgent care needs, an urgent care center, retail health clinic, or telemedicine visit may be an appropriate alternative for care if a primary care provider is unavailable. Members can use the Find a Doctor tool or visit MDLive’s website to learn more about these alternatives.
|Provider type||Access type||Appointment availability within|
|Primary care provider||Routine||2 weeks (4 weeks for routine physical)|
Minimum number of office hours per practice per week
Practices are encouraged to have at least one weekend day or evening session per week.
|Provider type||Practice size||Standard|
|Primary care provider||Solo||20 hours|
|Primary care provider||Dual||30 hours|
|Primary care provider||Group||35 hours|
|Capitated podiatry||20 hours|
|Specialist (other)||12 hours|
Maximum number of patients scheduled per hour per physician
Waiting times in the office should not exceed 30 minutes from the time of the scheduled appointment.
|Provider type||Number of patients|
|Podiatrist or chiropractor||6 patients|
|OB/GYN (routine)||6 patients|
Providers should respond to after-hours urgent/emergency problems within 30 minutes. Coverage must be provided 24 hours per day, 7 days per week for our members. Providers who use answering machines for after-hour services are required to include:
- Urgent/emergent instructions as the first point of instruction
- Information on contacting a covering provider
- A telephone number for after-hours physician access
Blue Distinction Centers® — recognized experience in specialty care
The Blue Distinction Specialty Care Program is a national Blue Cross and/or Blue Shield designation program recognizing healthcare providers that demonstrate expertise in delivering quality specialty care — safely, effectively and cost-efficiently. The goal of the program is to help consumers find both quality and value for their specialty care needs.
Blue Distinction Centers
The Blue Distinction Specialty Care Program includes two levels of designation:
- Blue Distinction Center: Healthcare providers recognized for their expertise in delivering specialty care.
- Blue Distinction Center+: Healthcare providers recognized for their expertise and cost-efficiency in delivering specialty care. Only those providers that first meet nationally established, objective quality measures for Blue Distinction Centers will be considered for designation as a Blue Distinction Center+.
What is specialty care?
Specialty care includes:
- Bariatric (weight-loss) surgery
- Cardiac care
- Cellular immunotherapy*
- Fertility care (physician designation)
- Gene therapy*
- Knee and hip replacement
- Maternity care
- Spine surgery
- Substance use treatment and recovery
*Only Blue Distinction designation available
Find a Blue Distinction Center
For a complete listing of the Blue Distinction Centers for specialty care nationwide, including those within the Independence Blue Cross provider network, please visit the BCBSA website.
Facilities that have attained the Blue Distinction Center designation will be marked in the online Find a Doctor tool.
Medical record keeping standards
Medical records facilitate the delivery of quality health care through the documentation of past and current health status, diagnoses, and treatment plans. As such, Independence Blue Cross (Independence) has established standards for medical records to promote efficient and effective treatment by facilitating communication and the coordination and continuity of care.
The Independence medical record standards policy is reviewed annually. The policy addresses confidentiality of medical records, medical records documentation standards, an organized medical record keeping system, standards for availability of medical records, maintenance and auditing of medical records, and performance goals to assess the quality of medical record keeping. Independence’s standards for medical record documentation are in addition to state and federal laws, including the requirements of the Health Insurance Portability and Accountability Act (HIPAA).
Each medical record should comply with the following standards:
Medical record content
- Significant illnesses and medical conditions indicated on the problem list
- Documentation of medications – current and updated
- Prominent documentation of medication allergies and adverse reactions; if there are no known allergies or history of adverse reactions, this is appropriately noted
- Food and other allergies, such as shellfish or latex, which may affect medical management
- Past medical history (for patients seen three or more times), including serious accidents, operations, and illnesses; for children and adolescents (18 years and younger), past medical history relates to prenatal care, birth, operations, and childhood illnesses
- For patients 12 years and older, appropriate notations concerning use of cigarettes, alcohol, and substance abuse (for patients seen three or more times, query substance abuse history)
- History and physical documentation includes subjective and objective information for presenting complaints
- Working diagnoses consistent with findings
- Treatment or action plans consistent with diagnoses
- Unresolved problems from previous office visits are addressed in subsequent visits
- Documentation of clinical evaluation and findings for each visit
- Appropriate notations regarding the utilization of consultants
- No evidence that the patient is placed at inappropriate risk by a diagnostic or therapeutic procedure
- Documentation of preventive services and risk screening
- Immunization record for children is up to date or an appropriate history is made for adults
Medical record organization
- Each page in the record contains the patient’s name or ID number
- Personal/biographical data include address, employer, home and work telephone numbers, and marital status
- All entries contain the author’s identification; author identification may be a handwritten signature, a unique electronic identifier, or initials
- All entries are dated
- The record is legible to someone other than the writer
Information filed in medical records
- All services provided directly by a primary care practitioner
- All ancillary services and diagnostic tests ordered by a practitioner
- All diagnostic and therapeutic services for which a member was referred by a practitioner (such as home health nursing reports, specialty physician reports, hospital discharge reports, and physical therapy reports)
- Laboratory and other studies are ordered, as appropriate
- Encounter forms or notes have a notation, when indicated, regarding follow-up care, calls, or visits; the specific time of return is noted in weeks, months, or as needed
- If a consultation is requested, there is a note from the consultant in the record
- Specialty physician, other consultation, laboratory, and imaging reports filed in the chart are initialed by the practitioner who ordered them to signify review; review and signature by professionals other than the ordering practitioner do not meet this requirement
- Consultation: abnormal lab and imaging study results have an explicit notation in the record of follow-up plans
- The existence of an Advance Directive is prominently documented in each adult (older than 18 years of age) member’s medical record; information as to whether the Advance Directive has been executed is also noted
Retrieving medical records
- Medical records are to be made available to the Plan as defined in the Professional Provider Agreement
Confidentiality of medical records
- Protected Health Information (PHI) is protected against unauthorized or inadvertent disclosure
- At a minimum, medical records must be maintained for at least ten years, or age of majority plus six years, whichever is longer
- Records are stored securely.
- Only authorized personnel have access to records.
- Staff receive periodic training in member information confidentiality
Maintenance of records and audits
Providers must maintain all medical and other records in accordance with the terms of their Professional Provider Agreement and the Provider Manual for Participating Professional Providers. When requested by Independence or its designated representatives, or designated representatives of local, state, or federal regulatory agencies, the provider shall produce copies of any such records and will permit access to the original medical records for comparison purposes within the requested time frames and, if requested, shall submit to examination under oath regarding the same. If a provider fails or refuses to produce copies and/or permit access to the original medical records within 30 days as requested, Independence reserves the right to require Selective Medical Review before claims are processed for payment to verify that claims submissions are eligible for coverage under the benefits plan.
Member rights and responsibilities
Commercial and Medicare Advantage member rights and responsibilities
Commercial member rights
- The members have a right to receive information about the health plan, its benefits, services included or excluded from coverage policies, participating practitioners/providers and members’ rights and responsibilities. Written and web-based information that is provided to the member will be readable and easily understood.
- The members have a right to be treated with respect and recognition of their dignity and right to privacy.
- The members have a right to participate in decision making regarding his/her health care. This right includes candid discussions of appropriate or medically necessary treatment options for their condition, regardless of cost or benefit coverage.
- The members have a right to voice complaints or appeals about the health plan or care provided, and to receive a timely response. The members have a right to be notified of the disposition of appeals/complaints and the right to further appeal, as appropriate.
- The members have a right to make recommendations regarding the organization’s member rights and responsibilities policies by contacting Customer Service in writing.
- The members have a right to confidential treatment of personally identifiable health/medical information. The members also have the right to have access to their medical record in accordance with applicable federal and state laws.
- The members have a right to reasonable access to medical services.
- The members have a right to receive health care services without discrimination based on race, ethnicity, age, mental or physical disability, genetic information, color, religion, gender, gender identity, sexual orientation, national origin, or source of payment.
- The members have a right to formulate advance directives. The Plan will provide information concerning advance directives to members and practitioners/providers and will support members through its medical record-keeping policies.
- The members have a right to obtain a current directory of participating practitioners/providers in the Plan’s network, upon request. The directory includes addresses, telephone numbers, and a listing of practitioners/providers who speak languages other than English.
- The members have a right to file a complaint or appeal about the health plan or care provided with the applicable regulatory agency and to receive an answer to those complaints within a reasonable period of time and to be notified of the disposition of an appeal or complaint and further appeal, as appropriate.
- The members have a right to appeal a decision to deny or limit coverage, first within the Plan and then through an independent organization for a filing fee as applicable. The members also have the right to know that their doctor cannot be penalized for filing a complaint or appeal on the member’s behalf.
- The members have a right to choose a primary care provider within the limits of covered benefits and availability within the Plan network. The members also have the right to refuse care from specific practitioners/providers.
- For members with chronic disabilities, they have the right to obtain assistance and referrals to practitioners/providers who are experienced in treating their disabilities.
- The members have a right to candid discussions of appropriate or medically necessary treatment options for their condition, regardless of cost or benefit coverage, in terms that members understand including an explanation of their medical condition, recommended treatment, risks of treatment, expected results and reasonable medical alternatives. If the members are unable to easily understand this information, they have the right to have an explanation provided to their next of kin or guardian and documented in their medical record. The Plan does not direct practitioners/providers to restrict information regarding treatment options.
- The members have a right to have available and accessible services, when medically necessary, including the availability of care 24 hours a day, 7 days a week for urgent and emergency conditions.
- The members have a right to call 911 in a potentially life-threatening situation without prior approval from the Plan and the right to have the Plan pay per contract for a medical screening evaluation in the emergency room to determine whether an emergency medical condition exists.
- The members have a right to continue receiving services from a practitioner/provider who has been terminated from the Plans’ network (without cause) in the timeframes as defined by the applicable state requirements. This continuation of care does not apply if the provider is terminated for reasons which would endanger the member, public health or safety, breach of contract or fraud.
- The rights afforded to members by law or regulation as a patient in a licensed health care facility include the right to refuse medication and treatment after possible consequences of this decision have been explained in language they understand.
- The members have a right to be free from balance billing by practitioners/providers for medically necessary services that are authorized or covered by the Plan except as permitted for copayments, coinsurance and deductibles, by contract.
- The members have a right to prompt notification of terminations or changes in benefits, services, or practitioner/provider network.
Commercial member responsibilities
- Members have the responsibility to communicate, to the extent possible, information the Plan, participating practitioners and practitioners/providers need in order to care for the member.
- Members have the responsibility to follow the plans and instructions for care that they have agreed on with their practitioners/providers. This responsibility includes consideration of the possible consequences of failure to comply with recommended treatment.
- Members have the responsibility to understand their health problems and participate in developing mutually agreed upon treatment goals to the degree possible.
- Members have the responsibility to review all benefits and membership materials carefully and to follow the rules pertaining to the health plan.
- Members have the responsibility to ask questions to assure understanding of the explanations and instructions given.
- Members have the responsibility to treat others with the same respect and courtesy expected for oneself.
- Members have the responsibility to keep scheduled appointments or to give adequate notice of delay or cancellation.
- The responsibility to pay deductibles, coinsurance, or copayments, as appropriate, according to the member’s contract.
- The responsibility to pay for charges incurred that are not covered under or authorized under the member’s benefit policy or contract.
- The responsibility to pay for charges that exceed what the plan determines are customary and reasonable (usual and customary, or usual, customary and reasonable, as appropriate) for services that are covered under the out-of-network component of the member’s benefit contract with respect to point of service contracts.
Medicare Advantage member rights and responsibilities statement
Medicare Advantage member rights
- The right to be treated with fairness, respect, and recognition of the member’s dignity and right to privacy.
- The member has the right to confidential treatment of personally identifiable health/medical information. The member also has the right to have access to his or her medical record in accordance with applicable Federal laws.
- The right to see Plan practitioners/providers and get covered services within a reasonable period of time.
- The right to get a treatment plan. The right to know treatment choices and participate with practitioners/providers in decisions about the member’s health care. The Plan does not direct practitioners/providers to restrict information regarding treatment options.
- The right to know how the doctors are paid.
- Get information in a way you understand from Medicare, health care practitioners/providers, and contractors.
- Get clear and simple information about Medicare to help you make health care decisions, including what is covered, what Medicare pays and how much you have to pay.
- The right to choose practitioners/providers, within the limits of covered benefits and availability within the health plans network and the right to refuse care from specific practitioners/providers.
- The right to a candid discussion of appropriate or medically necessary treatment options for the member’s medical conditions, regardless of cost or benefit coverage.
- The right to learn about treatment choices in clear language that you can understand and participate in treatment decisions.
- Get health care services in a language the member can understand and in a culturally sensitive way.
- Get emergency care when and where you need it.
- The right to have a choice of specialists among participating network practitioners/providers following an authorization referral or prior authorization as applicable, subject to their availability to accept new patients.
- The member has the right to receive health care services without discrimination based on race, ethnicity, age, mental or physical disability, genetic information, color, religion, gender, gender orientation, sexual identity, national origin, or source of payment.
- The right to use advance directives (such as a living will or a power of attorney).
- The member has a right to voice complaints or appeals about the health plan or care provided, and to receive a timely response. The member has a right to be notified of the disposition of appeals/complaints and the right to further appeal, as appropriate.
- The right to request an appeal to resolve difference with the Plan.
- The right to file complaints (sometimes called “grievances’), including complaints about the quality of your care.
- The right to get information about health care coverage and costs and to obtain information in other formats.
- The right to get information about the Plan, it services, its practitioners/providers and members’ rights and responsibilities.
- The right to make recommendations regarding the Plan’s Member’s Rights and Responsibilities Policy.
- The right to get a decision about health care payment, coverage of services or prescription drug coverage.
- Get a coverage decision or coverage information from the Plan before getting services.
Medicare member responsibilities
- The responsibility to give the Plan and practitioners/providers the information they need to provide care (to the extent possible)
- The responsibility to act in a way that supports the care provided to others and helps smooth the running of practitioners/providers offices and facilities.
- The responsibility to pay premiums and any cost-share the member may owe for covered services and meet their other financial responsibilities as described in the Evidence of Coverage.
- The responsibility to understand his or her health problems and participate in developing mutually agreed upon treatment goals to the degree possible.
- The responsibility to advise the Plan of any questions, concerns, problems, or suggestions.
- The responsibility to notify practitioners/providers that the member is enrolled in the health plan when seeking care (unless it is an emergency).
- The responsibility to notify the health plan if the member has additional health insurance.
- The responsibility to notify the health plan if the member moves out of the service area.
- The responsibility to follow the plans and instructions for care that they have agreed on with their practitioners/providers. This responsibility includes consideration of the possible consequences of failure to comply with recommended treatment.
Privacy and confidentiality
Protection of privacy in all settings
Independence Blue Cross has taken numerous steps to see that the personal information of our members is kept confidential and to prevent the unauthorized release of, or access to, this information. All employees annually receive training regarding the importance of protecting member information. All contracted providers are required to maintain confidentiality of member information and records in accordance with applicable laws.
Access to medical records
Independence does not maintain members’ medical records. The providers who create the records are responsible for maintaining them. Members can access and obtain such medical records from providers. Independence does maintain records that contain personal health information as it relates to coverage. Upon a member’s request, we will provide a summary of any of his or her personally identifiable information maintained by us, such as telephone number, address, etc. At any time, a member may request that we modify, correct, change, or update his or her personally identifiable information that we maintain by contacting us by mail or telephone.
Inclusion in routine consent
In certain situations, it may be necessary for us to maintain and release a member’s records, claims related information, or health-related information to third parties for health care operations in accordance with applicable laws and regulations. Once enrolled with us, we may maintain and release member records to third-party vendors to ensure that quality health care coverage is provided to the member, to perform our contractual obligations, or to fulfill a regulatory mandate. Please be assured that we will only release information in accordance with applicable laws and regulations.
Right to approve release of information
Member information will only be released to qualified recipients and in accordance with applicable state and federal laws.
Use of measurement data
At times we may use membership data to develop or enhance health benefits and services. Patient identity will be kept anonymous wherever possible.
Affirmative statement regarding physician incentives for utilization management decisions
It is the policy of Independence and its affiliates (“plans”) that all utilization review decisions are based on the appropriateness of health care services and supplies in accordance with the plans’ definition of medical necessity and the benefits available under the member’s coverage. Only physicians can make denials of coverage of health care services and supplies based on lack of medical necessity.
The nurses, medical directors, other professional providers, and independent medical consultants who perform utilization review services for the plans are not compensated or given incentives based on their coverage review decisions. Medical directors and nurses are salaried employees of the plans, and contracted external physicians are compensated on a per-case-reviewed basis, regardless of the coverage determination. The plans do not specifically reward or provide financial incentives to individuals performing utilization review services for issuing denials of coverage. There are no financial incentives for such individuals that would encourage utilization review decisions that result in underutilization.
If you have any questions or concerns about the quality of care received, you can reach us by calling the number on the back of your ID card.