On January 27, 2023, the Centers for Medicare & Medicaid Services released a State Health Official (SHO) letter, “Medicaid Continuous Enrollment Condition Changes, Conditions for Receiving the FFCRA Temporary FMAP Increase, Reporting Requirements, and Enforcement Provisions in the Consolidated Appropriations Act, 2023.” The SHO letter is the second in a series of guidance related to section 5131 of the Consolidated Appropriations Act, 2023 (CAA), which established a fixed end date for the Medicaid continuous coverage requirement, a gradual phase-down for the enhanced federal match, and new guardrails for mitigating coverage loss for individuals who continue to be eligible. This expert perspective reviews the additional detail and operational expectations of states during the unwinding of Medicaid continuous coverage as laid out in the SHO letter.
ACA Implications for State Network Adequacy Standards
Georgetown University Health Policy Institute – Sally McCarty and Max Farris
This brief, prepared by the Georgetown University Health Policy Institute, explores some of the discrepancies that can arise with varying network adequacy standards and provides examples of how some states have resolved such issues. Network adequacy refers to a health plan’s ability to deliver the benefits promised by providing reasonable access to a sufficient number of in-network primary care and specialty physicians, as well as all health care services included under the terms of the contract.
States have taken different approaches in regulating the adequacy of health plan networks based on their state-specific market. States have a variety of options available to maintain robust health insurance markets by balancing access needs with the goals of controlling costs and attracting a healthy number of insurers. Appendix A serves as a comparison table of different network adequacy standards and requirements. Appendix B provides a narrative description of network adequacy standards in California, Colorado, Delaware, Hawaii, Maryland, Minnesota, Montana, Texas, Vermont, Washington, and the Federally-facilitated Marketplace.