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:

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Annual Filing


Annual Filing Instructions

Population Density by Zip Code

2019 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 2019 access plans.


2018 Executive Summary Form Filings

2020 Meeting Schedule


​Next Meeting

Monday, April 20, 2020 2:00 p.m. - 4:00 p.m.


Maryland Insurance Administration
24th Floor Hearing Room
200 St. Paul Place
Baltimore, MD 21202

Scheduled Meetings:


Previous Meetings

December 18, 2019

November 5, 2019

October 23, 2019

2019 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, 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 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 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 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 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 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.

2019/2020 Hearing Testimony

  • 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.

2016-2017 Workgroup

  • ​2016-2017 Network Adequacy Regulations Page
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