Delegation Governance Intelligence
Every delegation is a promise on paper. Prove you're keeping it.
Confidential · May 2026
Health plans delegate clinical and administrative functions to third parties. Nobody watches what happens next.
The industry answer has been the same for twenty years: annual oversight. Once a year, collect reports, review SLAs, file the results. A delegate that begins underperforming in February will not be assessed until January. Eleven months of degraded performance with nobody watching.
The annual cycle cannot catch problems in time. It was never designed to.
The 2026 HPMS audit updates shifted from form-based validation to evaluating whether compliance programs actually govern delegated work. Ceremonial oversight will be flagged. CMP totals through 2025 already exceed the combined total for 2021 through 2024.
DGS defines the minimum requirements for structured, continuous delegation oversight. It specifies what to monitor, how often, at what thresholds, with what response protocols, and with what documentation.
Covenant is the intelligence layer that operationalizes DGS. It replaces spreadsheet-based annual oversight with threshold-based continuous governance.
CMS audits all 550 MA contracts now. Delegation oversight is a top finding. Your spreadsheet is a liability.
Eight governance triggers fire automatically when thresholds breach. Every trigger specifies the required response, the responsible party, and the documentation generated.
Composite score for every delegated entity on a 0-100 scale. Weighted by function criticality. Updated continuously as monitoring data arrives.
Three monitoring tiers run simultaneously:
Real-time automated data feeds. Claims turnaround, UM decisions, call center metrics, credentialing processing. System surfaces exceptions.
Monthly or quarterly structured assessments. Claims accuracy audits, UM appropriateness reviews, quality measure validation. Defined sampling methodology.
Triggered by governance events. Regulatory actions, leadership changes, data failures. May override the periodic schedule temporarily.
Every output is audit-ready and built from the DGS methodology.
Audit firms show up once a year, find problems, and leave. Covenant runs continuously. Problems surface in real time with documented response protocols already attached.
TPA platforms track operational metrics. They do not govern. A metric that breaches a threshold in a dashboard still requires a human to notice, interpret, and act. That gap is where regulatory exposure accumulates.
Spreadsheets store data. They do not trigger responses. A plan with 10 delegates, 5 functions each, 6 metrics per function, monitored monthly generates 3,600 data points per year. Nobody governs that in Excel.
Covenant produces the documentation trail that regulators actually want to see. Not a binder assembled the week before an audit. A living record that proves continuous governance happened.
No integration required. Covenant operates on the data you already produce. The governance layer wraps around your existing delegation infrastructure.
45 days from contract to live governance.
Spreadsheet tracking becomes threshold-based triggers. Annual desk audits become continuous monitoring. Key-person risk becomes systematic governance. Binder assembly becomes automated evidence packaging.
Your delegates. Your contracts. Your existing data feeds. Your compliance staff. Covenant structures the oversight program around the infrastructure you already have.
Joe Nalley — Staff VP, Carelon Growth (Elevance Health), owning six specialty risk books (MSK, Oncology, CHF, Maternity, Autoimmune, Dementia) across $50B+ in spend. Built and sold a 13-location health system (200,000+ patients) and ClearBill ($9.2M returned to payers in its first six months). Built the governance methodology applied across 65,234 specialty patients that Covenant extends to delegation oversight.
Part of the Corridor family: Cadence (specialty governance), Curated (episode-based care), Caliber (claims verification), Crescent (women's health continuum).
30-minute walkthrough. I'll bring the regulatory crosswalk for your delegation model and show you where the gaps are.
No integration required.
Covenant operates on existing data. 45 days to live governance.
covenantdgs.com