Dear Commissioners Praeger and Nickel:
The undersigned organizations representing hospitals, physicians, and other health care providers
serving both children and adults, as well as health care consumers and other stakeholders, wish
to thank you for the opportunity to provide the perspective of our members on the development
of meaningful standards for network adequacy. As the National Association of Insurance
Commissioners (NAIC) continues the process to revise its 1996 Managed Care Plan Network
Adequacy Act (Model Act #74), we have joined together to make the following
recommendations. We believe that these issues must be addressed in the final Model Act:
- Provider networks must include a full range of primary, specialty and subspecialty
providers for children and adults to ensure that consumers have access to all covered
services, at every level of complexity, without administrative or cost barriers; - Regulators must actively review and monitor all networks using appropriate quantitative
and other measurable standards; - Appeals processes must be fair, timely, transparent and rarely needed. Appeals and other
out-of-network arrangements must not be used as an alternative to an adequate network
for all covered services;
…
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