RE: Managed Care Plan Network Adequacy Model Act
Dear Commissioners Sevigny, Kreidler, and Members of the Health Insurance and Managed
Care (B) Committee:
The undersigned organizations representing health care consumers, physicians, hospitals and
other health care providers write to request your consideration of our shared priorities for
incorporation into the final National Association of Insurance Commissioners (NAIC) Managed
Care Plan Network Adequacy Model Act (Model Act).
Our organizations strongly support many of the important new provisions in the current draft and
appreciate the work of the NAIC’s Network Adequacy Model Review (B) Subgroup to craft the
bill in an inclusive manner. However, we believe that further attention to the issues outlined
below are essential to ensure that the Model Act fulfills the pressing needs of children and adults
to access all covered health care services. Specifically, we respectfully urge the B Committee to
focus on three areas:
- Active approval of networks prior to products going to market.
- The use of quantitative measures to determine network adequacy.
- Regulation of tiered networks to prevent discriminatory network design.
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