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 a deadline for the submission of written comments will be established at a later date.