The MPS signed on to Legal Action Center comments on network adequacy regs, COMAR § 31.10.44, along with certain other members of the Maryland Parity Coalition.  The comments include a recommendation to retain the three quantitative metrics – geographical travel distance, appointment wait time and provider-patient ratio – as well as the numerical standards for each metric. Revisions to the metrics are premature, pending full disclosure from carriers regarding their efforts to contract with MH and SUD providers and the reasons for non-compliance with the existing metrics. The goals of the comments are to provide greater granularity to assess the availability of MH and SUD providers, provide greater transparency regarding the carriers’ contracting efforts, and ensure that the MIA can assess carrier provider networks for compliance with the Parity Act.  The detailed recommendations incorporate and respond to the results from two years of annual filings by carriers regarding their provider networks.