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Network Adequacy
Frequently Asked Questions
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Can QHPs request service areas at a county or partial county area level based on network adequacy?
DIFS grants partial service area approval to issuers who demonstrate network adequacy in a portion of a service area. Issuers should refer to DIFS annual Form and Rate Filing Bulletin for specific details concerning partial service area approval.
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QHPs will not be required to request service area for all of the counties identified in each rate region.
Yes, this is true.
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Will DIFS continue to review and assess network adequacy or will CMS be making the assessment in Michigan?
CMS has deferred to states performing plan management functions the authority to conduct review of network adequacy. Please review the Michigan Network Adequacy Guidance posted annually on the DIFS website and in SERFF under the Plan Management Tab.
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Is it correct that within HIOS, an entity that is accredited by NCQA, URAC, or AAAHC does not need to make any network adequacy filings, but that does not exempt an entity from filing the Michigan Network Data template?
No, accreditation does not relieve the issuer from network adequacy filings. The following are required templates pertaining to network adequacy:
On Marketplace: (1) Network ID Template (Federal); (2) Service Area Template (Federal); (3) Michigan Network Data Template (Michigan); and (4) Essential Community Providers (ECP).
Off Marketplace: (1) Network ID Template (Federal); (2) Service Area Template (Federal); and (3) Michigan Network Data Template (Michigan). The ECP template is not required for Off Marketplace.
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To complete the Michigan Network Data template, must we list every single provider within our networks? Among our three networks, this means we will be inputting over 33,000 providers, their addresses, specialties, etc.
Yes, every provider must be listed. The template allows data to be downloaded. For specific questions on the template contact Sara Beland at 517-284-8710.
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Please explain the requirements related to attestations.
Attestations will be in PDF format that will be submitted in SERFF as part of the issuer's binder(s) submission. Attestation(s) will be submitted under the Supporting Documentation tab in the binder filing. There are no specific requirements relative to the authorized signatures required; however, the issuer's signatory should have the appropriate authority as established by the issuer's policies.