Updates to Exclusion Sanction Questions on Provider Enrollment Applications

Effective Sept. 28, 2025, NCTracks will update initial, re-enrollment, re-verification and manage change request (MCR) provider application Exclusion Sanction questions. The new questions (N, Q, R and S) are required to meet National Committee for Quality Assurance (NCQA) standards. Providers must respond to these questions on all applicable provider enrollment applications initiated on or after Sept. 28, 2025.

The current question reads:

  • N. Does the enrolling provider have any medical, chemical dependency or psychiatric conditions that might adversely affect your ability to practice medicine or surgery or to perform the essential functions of your position?

The current question will be replaced with the following, and new questions Q, R, S will be added:

  • N. Is the enrolling provider currently engaged in the illegal use of drugs?

“Currently” means sufficiently recent to justify a reasonable belief that the use of drugs may have an ongoing impact on one’s ability to practice medicine. It is not limited to the day of, or within a matter of days or weeks before the date of application but instead refers to conduct recent enough to indicate the individual is actively engaged in such use. “Illegal use of drugs” refers to drugs whose possession or distribution is unlawful under the Controlled Substances Act, 21 U.S.C. §812.22. It does not include the use of a drug taken under supervision by a licensed health care professional, or other uses authorized under federal law. The term does include unlawful use of prescription-controlled substances.

  • Q. Does the enrolling provider use any chemical substances that would in any way impair or limit the ability to practice medicine and perform the functions of the job with reasonable skill and safety?
  • R. Does the enrolling provider have any reason to believe that they would pose a risk to the safety or well-being of patients?
  • S. Is the enrolling provider unable to perform the essential functions of a practitioner in the area of practice even with reasonable accommodation?

Important Notes

Answering these questions affirmatively does not automatically disqualify a provider from NC DHHS program participation. However, failure to disclose can result in denial of the application and subsequent termination from all NCDHHS programs.

To avoid delays or additional applications, providers are strongly encouraged to:

  • Submit all draft applications before Sept. 27, 2025.
  • If drafts remain after the go-live date, be prepared to start a new application under the updated requirements.

Draft applications in the system at the time of implementation will be deleted. Providers should submit draft applications before Sept. 28, 2025, to prevent loss of data.

  • Please contact the NCTracks Contact Center at 1-800-688-6696 with any questions. 

 

 

 

 

 

 

 

 

 

 

 

 

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