Continuing its longstanding advocacy in this area, the MPS joined the Legal Action Center and fifteen other organizations in comments on the Maryland Insurance Administration’s (MIA) proposed regulations on network adequacy standards.  The proposed regulations focus on requiring carrier reporting of:

• substance use disorder (SUD) and mental health (MH) practitioners and facilities and services with greater granularity in the travel distance and appointment wait time metrics;
• coverage and availability of in-person SUD and MH services to ensure that Marylanders have a choice to see a practitioner in-person, via telehealth or a combination of both;
• carrier contracting efforts when network metrics have not been satisfied; and
• all metrics through standardized definitions, methodologies, and templates.

While the MIA’s proposals largely address these issues, the MPS and other groups request revisions to clarify the carrier’s obligation to submit waiver information if it fails to meet metrics based on provider availability of in-person services, without consideration of the proposed telehealth credit. We also continue to oppose adoption of a telehealth credit pending additional data gathering and analysis, which is consistent with the anticipated two-year extension and study of audio-only telehealth and payment parity requirements (see SB 534) and with HHS recommendations on telehealth for qualified health plans.

MPS also supports the proposal to require carriers to submit detailed data on network coverage of SUD and MH providers who deliver in-person services, out-of-network provider utilization, requests for and use of single-case agreements, and inclusion of practitioners who meet the health needs of Marylanders across racial, ethnic, gender, sexual orientation, gender identity and disability. We urge the MIA to make this information available to the General Assembly via aggregate data reports and briefings to inform policy development and ensure transparency for the public.

Please click here for detailed comments.