Dear Mr. Nickel:
The Alliance of Specialty Medicine and its member organizations thank you for the
opportunity to provide input on the Draft Individual Market Health Insurance Coverage
Model Regulation and the Draft Small Group Market Health Insurance Coverage Model
Regulation. The Alliance is a coalition of medical specialty societies representing more than
100,000 physicians and surgeons dedicated to the development of sound federal healthcare
policy that fosters patient access to the highest quality specialty care. Regarding these
draft models, our members are particularly concerned about patient access and
affordability issues related to network adequacy and out of network cost-sharing
provisions.
The draft models present an opportunity to ensure that patients are not caught off guard
about the availability of physicians, particularly specialist physicians often excluded from
networks, and cost-sharing provisions related to the services provided by those physicians
who are considered out-of-network by a particular plan.
- The Alliance of Specialty Medicine urges NAIC to incorporate model language that
requires health plans to ensure patients have access to specialists and subspecialists
as part of the health plan in which they are enrolled. This may require plans to
better identify specialty physician specialties and subspecialties to ensure the
necessary mix of providers are available for enrollees.
…
Read full letter here
