Specialty Physicians Express Support for Federal Network Adequacy Standards
The Alliance of Specialty Medicine (“Alliance”) urged the Centers for Medicare and Medicaid Services (CMS) to finalize its proposals aimed at ensuring adequate provider networks in Marketplace plans. In formal comments to the 2023 Notice of Benefit and Payment Parameters (“Payment Notice”) proposed rule, the specialty medical societies highlighted challenges consumers face in accessing specialty medical care as issuers eliminate or block specialty and subspecialty physicians from their networks as a cost-saving measure. Too often, consumers do not realize the limitations of their plan’s provider network until an unexpected medical condition arises. The Alliance also expressed concern about the manner in which specialists are removed from networks, usually based on flawed performance metrics, and leave specialty providers little recourse for network re-entry. The specialists recommended that CMS take a number of steps to address narrow networks, including requiring plans to account for the full range of specialty and subspecialty providers and to provide reasonable notice regarding termination and options for network re-entry, among other things.
The Alliance also addressed other proposals in the 2023 Payment Notice focused on discrimination, with a focus on adverse tiering that limits access to prescription drugs for chronic health conditions or highly specialized surgical care. The Alliance registered their support for policies that would require plans to use clinical evidence for nondiscriminatory benefit design.