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Association Letter Calls for Marketplace Network Adequacy

In a Dec. 1 letter to federal regulators, America’s Essential Hospitals expressed continued concerns about qualified health plan (QHP) network adequacy in federally facilitated marketplaces.

The letter responds to a draft 2018 letter to marketplace issuers from the Centers for Medicare & Medicaid Services Center for Consumer Information and Insurance Oversight (CCIIO). In its letter to CCIIO Director and Marketplace CEO Kevin Counihan, America’s Essential Hospitals asserted that CCIIO should:

  • require issuers to offer good-faith contracts to all essential community providers (ECPs) and should develop specific requirements for including essential hospitals;
  • monitor contracts offered by QHP issuers to ensure payment rates offered to ECP hospitals are adequate to support the unique services — such as trauma, burn, neonatal, and other specialty services — these essential hospitals provide; and
  • ensure reviews for network adequacy evaluate QHPs, through the reasonable access review standard, to verify plan networks include hospitals that offer all of the essential services on which low-income and medically underserved patients rely.

Contact Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Michelle Rosenfeld is manager of communications at America's Essential Hospitals.

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