Decreased HSD Tables Application Requirement Now Leads to CMS Network Adequacy Review Later

Part C applications may have decreased requirements for the submission of a key management staff organizational chart and Health Service Delivery (HSD) tables, based upon the proposed 2019 application, published August 1, 2017.  Plans will have to instead attest that their network meets CMS adequacy requirements prior to marketing for the upcoming plan year and further attest that they will maintain this level of network adequacy.

This change is a huge benefit to an organization that is going through the initial application, as it extends the amount of time a plan has to finalize its network contracts.  In past years, contracts had to be finalized at the time of the application submission; however, this change gives plans until open enrollment to secure all contracts.

Plans not going through a new application or service area expansion (SAE) should be aware that this change means that all Medicare Advantage (MA) organizations will be subject to reviews of their full network on a three-year cycle.  This signals likely more ongoing scrutiny of network adequacy by CMS. Provider directory accuracy is already being audited with compliance actions for noncompliance. We believe that network adequacy may well become the next focused audit. CMS now has the ability for plans to upload their network via HPMS to check their compliance to access standards. It would be easy for CMS to notify a plan that they must upload their tables for review at any time, so it’s important that plans remain diligent in their network adequacy oversight and take actions promptly to remediate any deficiencies.