NADP will submit comments this week in response to a Centers for Medicare and Medicaid Services (CMS) paperwork reduction act notice that
outlines some technical specifications around an Exchange requirement
for carriers to submit machine-readable data for provider networks. This
requirement was finalized as part of theFinal Benefit and Payment Parameters. Presumably,
the files could be used to create search functions within itself. However, these files will also be shared with
third-parties to “create innovative and informative tools to help
enrollees better understand the plan’s provider network.

NADP comments express the concern shared by members including:

  • An exemption for off Exchange certified dental plans,
  • A delay overall for dental networks until 2017, and
  • The transfer of data to third-parties.

There is very
little information at this time on who the third-parties may be, what
the agreement between those parties and CMS will entail, and thus the
ability for third-parties to display, manipulate, distribute or sell the

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