The Affordable Care Act deals with network adequacy in very vague terms by laying out broad parameters within which state officials must operate to provide adequate and timely access to covered benefits. A regulation that implemented the law did not add much specificity to the statutory requirements. So, it’s not surprising that as soon as the federal and state marketplaces became operational complaints about narrow networks and other network adequacy problems began to surface. In response to these developments, state regulators are revisiting their network adequacy standards with an eye toward revising them to address new requirements and recent complaints.
To assist with that effort, members of the CHIR faculty who participate in the State Health Reform Assistance Network have developed a Network Adequacy Planning Tool for states to use when analyzing and updating their network adequacy standards. The tool provides a framework for state thinking and discussion around the revision of current network standards and development of new standards. It lays out 10 areas of consideration that should be addressed in a comprehensive set of network adequacy standards. A section is included to list any formulae states may want to use to assess network adequacy. Within each area of consideration, multiple regulatory and monitoring options are presented.
The options include those that are currently employed by various states and those suggested in recent media reports and commentary on the issue, as well as those suggested by developers of the resource. The form can be downloaded and can be adapted to state-specific preferences and needs. The Network Adequacy Planning Tool will be updated periodically as new options and considerations are discovered.
Another new resource recently developed by CHIR faculty for the State Network program is the Mental Health Parity and Addiction Equity Act (MHPAEA) Checklist and Certification. This resource is a form that regulators can require insurers to complete to certify that their forms comply with MHPAEA requirements. If the form being filed doesn’t meet a requirement, the certification requires a complete explanation of the shortcoming. Another new aid, the Issuer EHB Crosswalk and Certification, can be used by state regulators to require insurers filing forms to provide a description for each federally required essential health benefit and state mandate as it appears in the filed form, as well as the page number where the benefit description can be found in the form.
These resources, along with updated versions of four Form Review Checklists (for individual, small group, stand-alone dental, and catastrophic plan form filings) developed by CHIR faculty in 2012 and 2013, will be reviewed and demonstrated in a State Network Webinar to be held on April 17, 2014 at 2:00 p.m. Interested regulators and other parties can learn more about the Webinar by clicking here.