Insurers and consumer representatives are disagreeing about when the National Association of Insurance Commissioners should revise its suggested health plan provider network standards.

America’s Health Insurance Plans wants the NAIC to put off work on the Managed Care Network Adequacy Model Act, to give insurers time to see how plans with small networks perform both on and off the new health insurance exchanges.

Moving too early could hurt insurers’ efforts to create plans with efficient, high-quality networks, Colleen Gallaher, an AHIP state policy specialist, said in a comment letter. 

But the people who officially speak for consumers in NAIC proceedings responded in their own comment letter that the NAIC should put revising the network adequacy model at the top of its to-do list.

The consumer reps note that the NAIC has not updated the network adequacy model since it was adopted in 1996.

PPACA sets network standards for all exchange plans, but the NAIC model applies only to managed care plans, the reps add.

“Network adequacy problems can also mask other problems,” the reps write.

In some cases, the reps say, network problems can be a sign of unfair marketing practices, or plan or provider insolvency.

Gallaher and the consumer reps sent their letters to the NAIC’s Regulatory Framework Task Force. The task force, an arm of the NAIC’s Health Insurance and Managed Care Committee, has been asking for public comments on which NAIC health insurance models the NAIC should update first.

The NAIC is an association for state insurance regulators. It has no direct ability to change state laws and regulations, but state lawmakers and regulators often base insurance policy changes in their jurisdictions on NAIC models.

AHIP put updating the Group Health Insurance Definition and Insurance Standard Provisions Model Act at the top of its to-do list. The group ranked updating the network model 15th on a list of 17 models.

The consumer reps asked the task force to consider revising a total of six models.

The reps asked for action on four models that may affect hospital indemnity products, critical illness insurance products and other products that fall outside the jurisdiction of most PPACA major medical requirements.

Regulators should make sure that consumers know when products meet PPACA major medical coverage requirements and help them avoid coverage mandate penalties and when the products fail to meet PPACA standards, the reps say. 

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