Network Adequacy Regulations Information

Written submissions will be considered public documents and will be posted to the Maryland Insurance Administration website.


Any questions or comments on Network Adequacy Regulations can be sent to: networkadequacy.mia@maryland.gov

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Annual Filing

 

Annual Filing Instructions

Population Density by Zip Code

2020 Executive Summary Form Filings

Please note: the information contained in the executive summary forms provided below has not yet been reviewed by MIA staff for accuracy or completeness. The preliminary information reported below may be subject to change after the MIA completes its review of the 2020 access plans.

Aetna Health and Life Insurance Company
Aetna HMO
Aetna PPO
CareFirst of Maryland Access Plan
CareFirst BlueChoice Access Plan
Cigna Health and Life Insurance Co.
Connecticut General Life Insurance Co.
Golden Rule Insurance Company
Group Hospitalization Medical Services Access Plan
Kaiser Foundation of the Mid-Atlantic States
KPIC 2020 Network Adequacy Access Plan
MLH Choice-ChoicePlus (Updated September 30, 2020)
Nexus ACO (Updated September 30, 2020)
OCI (Updated September 30, 2020)
UHCMA Choice-ChoicePlus (Updated September 30, 2020)
UHCMA Core (Updated September 30, 2020)
UHCMA Navigate (Updated September 30, 2020)
UHIC Choice-ChoicePlus (Updated September 30, 2020)
UHIC Core (Updated September 30, 2020)
UHIC Navigate (Updated September 30, 2020)
UHIC Navigate CVS (Updated September 30, 2020)
UHIC Options PPO (Updated September 30, 2020)
Well Fleet (Updated July 16, 2020)

2019 Executive Summary Form Filings

BlueChoice - Updated December 27, 2019
Group Hospitalization - Updated December 27, 2019
CareFirst of Maryland - Updated December 27, 2019

Connecticut General Life Insurance Co - Revised July 23, 2019
Aetna ALIC 2019 Executive Summary - Updated March 26, 2020
Aetna AHI 2019 Executive Summary - Updated March 26, 2020
Aetna AHLIC 2019 Executive Summary - Updated March 26, 2020

Cigna Health and Life Insurance Co. - Revised July 23, 2019
Golden Rule Insurance Co. - Updated March 25, 2021
Kaiser Permanente Insurance Company Network Adequacy - Updated March 23, 2021
CareFirst Medical
Kaiser Foundation Health Plan of the Mid-Atlantic States Network
Optimum Choice - Revised March 25, 2021

United HealthCare Insurance Company Choice Plus - Updated March 25, 2021

Mamsi Life and Health Insurance Co. - Updated March 25, 2021

United HealthCare Of the Mid-Atlantic(CHOICE)

United HealthCare Insurance Company (CORE) - Updated March 24, 2021

United HealthCare Of the Mid-Atlantic (CORE) - Updated March 25, 2021

2018 Executive Summary Form Filings

2021 Meeting Schedule

 

​Next Meeting (Printer Friendly)

The next public meetings to discuss potential revisions to the network adequacy regulations under COMAR 31.10.44 will be held virtually
 
June 18, 2021
10:00 A.M. to 1:00 P.M.
Zoom Webinar video conference: https://www.zoomgov.com/j/1603379277
Dial-in number: (833) 568-8864 (Toll Free)
Webinar ID: 160 337 9277
(Please see below for speaker registration information.)
 
                          
If you would like to present or offer public comments during the virtual meetings, please  notify the MIA in advance by submitting your request to david.cooney@maryland.gov. 
 
To the extent that time and technology permit, the MIA will hear from unregistered participants who access the Zoom Webinar platform. 

The Administration continues to solicit information from interested parties on whether the current filing process and existing standards are sufficient, appropriate and reasonable. Individuals or organizations who wish to submit written testimony should submit it to networkadequacy.mia@maryland.gov.


Previous Meetings

May 28, 2021
View meeting HERE
Agenda

December 18, 2020
View meeting HERE
Agenda

August 5, 2020
Agenda

April 20, 2020
Agenda

December 18, 2019
Agenda

November 5, 2019
Agenda

October 23, 2019
Agenda

2021 MIA Staff Questions To Interested Parties

 

In preparation for the network adequacy public meeting on June 18, 2021 that will focus on telehealth, MIA staff would appreciate your comments on the following:

In preparation for the network adequacy public meeting on June 18, 2021 that will focus on telehealth, MIA staff would appreciate your comments on the following:
 
1) The MIA acknowledges that consumer choices and preferences between in-person services and telehealth services are critically important considerations when determining whether an individual enrollee has access to needed health care services. However, the existing quantitative network adequacy standards that apply to in-person services and that are measured on an aggregate basis for a carrier’s entire network are based solely on clinical appropriateness, and do not account for individual enrollee preference. When measuring the quantitative network adequacy standards for the entire network, what is the rationale for why enrollee preference must be taken into account for clinically appropriate telehealth services, when this is not taken into account for clinically appropriate in-person services?
 
2) Carriers have contended that a provision that only allows telehealth services to count toward satisfaction of the network adequacy standards when an individual enrollee elects to use telehealth is unreasonable and extremely difficult to operationalize. If it is not operationally feasible to include enrollee preference with respect to telehealth when measuring compliance with the quantitative network adequacy standards on an aggregate basis, what are suggestions for how the network adequacy standards can otherwise still account for enrollee preference on an individual basis to ensure all enrollees have access to services that meet their needs?
 
3) Multiple stakeholders have proposed that carriers should be awarded a telehealth credit of up to 10% toward satisfaction of either the wait time standard or the travel distance standard. The Medicare Advantage network adequacy standards have been referenced as a model for this provision. Under the Medicare Advantage standard, a carrier may receive the credit merely by contracting with telehealth providers in particular specialties. 
(a) If Maryland considers adopting some form a telehealth credit, what additional or alternative criteria should be required prior to granting the credit to ensure telehealth is available and accessible to enrollees who need it?

(b) If a telehealth credit is applied toward satisfaction of a network adequacy standard, how can the regulations ensure that the credit is only awarded in situations where a telehealth service is clinically appropriate, available, and accessible to enrollees for the particular medical specialty, geographic area, and/or appointment type where the applicable standard is not met?  For example, if the travel distance standard is not met for dermatology in the rural geographic areas, it would not appear appropriate to even consider awarding a telehealth credit unless, in the specific rural zip codes where the standard is not met, the carrier offers telehealth services from in-network dermatologists, and the technological infrastructure to support the delivery of telehealth exists in those zip codes. Will carriers be able to gather the data and resources necessary to gauge telehealth accessibility at this level? What standards or criteria can be added to the regulations to address this issue?
While these questions will be discussed at the June 18, 2021 meeting, the MIA will continue to accept written responses to these questions for a 30-day period following the meeting.  Please submit your responses to networkadequacy.mia@maryland.gov.

2019-2021 Hearing Testimony

 
  • View comments submitted by APTA.
    August 19, 2020
  • View comments submitted by CareFirst.
    August 19, 2020
  • View comments submitted by Kaiser Permanente.
    August 19, 2020
  • View comments submitted by the League of Life.
    August 19, 2020
  • View comments submitted by the Legal Action Centers.
    August 19, 2020.
  • View comments submitted by MD Coalition of Families.
    August 19, 2020
  • View comments submitted by MDDCSAM.
    August 19, 2020
  • View comments submitted by MedChi.
    August 19, 2020
  • View comments submitted by the Maryland Academy of Nutrition and Dietetics
    August 4, 2020
  • View comments submitted by the Maryland Psychiatric Society January 22, 2020.
  • View comments submitted by the Maryland Assembly on School-
    Based Health Care January 19, 2020 
  • View comments submitted by American Psychiatric Association January 13, 2020.
  • View comments submitted by Maryland Academy of Nutrition and Dietetics December 18, 2019.
  • View comments submitted by Legal Action Center December 19, 2019.
  • View comments submitted by Community Behavioral Health Association of Maryland December 12, 2019.
  • View comments submitted by Maryland Assembly on School-Based Health Care November 12, 2019.
  • View comments submitted by Maryland Society of Pathologists November 4, 2019.

2019-2020 MIA Staff Questions To Interested Parties

 
The Maryland Insurance Administration is accepting comments on all aspects of the network adequacy regulations in COMAR 31.10.44. In addition to the questions posed in the October 23, 2019 meeting agenda, MIA staff would appreciate comments on the following:
 
In the definitions section in COMAR 31.10.44.02, should a definition for any of the provider types listed in the travel distance standards be included?
 
Do the charts of travel distance standards in COMAR 31.10.44.04 include the appropriate mix of providers?  Should any providers be added (e.g. child psychiatrist) or removed, and why?
 
Are the current mileage metrics for the travel distance standards in COMAR 31.10.44.04 appropriate?
 
Should carriers be required to comply with the travel distance standards for 100% of enrollees, or should the threshold be 95% to be consistent with the appointment waiting time standards, and why?
 
Should the regulations be revised to require that travel distance standards are based on “road travel distance”? Why or why not?
 
For enrollees covered under student health plans, should the regulations mandate or allow that the school’s address be used for determining travel distance standards?
 
For the essential community provider standard, COMAR 31.10.44.04C requires that a provider panel “shall include 30 percent of the available essential community providers in each of the urban, rural, and suburban areas.”
 
Should the regulation be revised to require a standardized methodology for calculating the 30% inclusion standard by geographic region?
 
Should carriers be required to provide a list of all contracted ECPs within their network for each provider panel?
 
Should the regulations require a standardized methodology to measure wait time standards, and if so, what methodology?
 
Are the current time period metrics for the waiting time standards in COMAR 31.10.44.05 appropriate based on the availability of healthcare providers in Maryland?
 
The Following Two Questions have been Added Effective December 3, 2019
 
House Bill 599 of the 2019 legislative session, effective January 1, 2020, requires carriers to use the most recent edition of the American Society of Addiction Medicine treatment criteria (“ASAM criteria”) for all medical necessity and utilization management determinations for substance use disorder benefits.  Are revisions to the network adequacy regulations in COMAR 31.10.44 necessary to ensure that a carrier’s network is sufficient to provide coverage at all levels of care indicated by the ASAM criteria?  If so, what specific standards or metrics should be established based on the ASAM criteria?

It has been noted that the definition of “essential community provider” in the plan certification regulations for the Maryland Health Benefit Exchange expressly includes school-based health centers, but the corresponding definition in the network adequacy regulations for the Maryland Insurance Administration does not.  Are there any potential adverse consequences for consumers or significant carrier concerns with revising the essential community provider definition in COMAR 31.10.44.02B(6) to expressly include school-based health centers?
 
Please note that the deadline for the submission of written comments is August 19, 2020.

2016-2017 Workgroup

 
  • ​2016-2017 Network Adequacy Regulations Page

Draft Regulation

  Title 31 Maryland Insurance Administration
Subtitle 10 Health Insurance - General
Chapter 44 Network Adequacy
View the Draft Regulation: 31.10.44.02
Comments close December 4, 2020​
Aetna Comments - December 4, 2020
AHIP Comments - December 4, 2020
APTA MD Comments - December 4, 2020
CareFirst Comments - Deceber 4, 2020
Cigna Comments - December 4, 2020
HEAU Comments - December 3, 2020
KPMAS Comments - December 4, 2020
League of Life and Health Insurance Comments - December 4, 2020
Legal Action Center Comments - December 4, 2020
Leni Preston Comments - December 4, 2020
MAND Comments - December 4, 2020
Maryland Hospital Association Comments - December 4, 2020
MedChi Comments - December 4, 2020
MPA Comments - December 4, 2020
MSA Comments - December 3, 2020
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