NADP submitted comments this month to the Ohio Department of Insurance (ODI) responding to draft rules
on provider network disclosures. The letter recommends the ODI
specifically exclude standalone dental plans from application and
addresses areas where dental and medical networks differ, as well as
identifies draft provisions that would increase administrative costs and
thus premiums without added benefits to the consumer.

According to its Common Sense Initiative (CSI) Business Impact Analysis (BIA),
ODI drafted the rule in response to consumer complaints regarding lack
of accurate provider network information when shopping for health
insurance plans both prior to and after enrollment. Complaints specific
to dental coverage are not provided. ODI also conducted internal reviews
of provider directories and observed inconsistencies and saw a need for
improvement. More on the stakeholder outreach is described on page 3 of
the BIA.

benefit plan” is defined within the draft regulation on page 1 and also
“means a limited benefit plan” with numerous exceptions. Supplemental
coverage (as described in section 3923.37 of the Revised Code),
specified disease, or vision care are excluded from application. Dental
is not specifically mentioned. Due to the unique position of stand-alone
dental plans and dental provider networks, NADP has urged the ODI to
specifically exclude stand-alone dental plans within the definition of a
“health benefit plan” as is done similarly for other HIPAA-excepted

The draft regulations
focus on two subject areas: Provider Directories and Out-of-Network
Coverage. Among other requirements, provider directories must be
reviewed and updated at least quarterly and must display the most recent
date of update. The directory must be available to enrollees in paper
copy form upon request and as soon as reasonably practicable (within 10
business days of request). Once an issuer is made aware of an addition,
expiration or termination of a provider or facility, the directory must
be updated within 15 business days of the effective date of such change.
The term “aware” is clarified in this version of the draft rule. There
are also specific data points to be included for each provider and
facility listed in the directory for each network.

Thanks to
volunteers from the Commission on Advocacy Policy (CAP) and Government
Relations Workgroup (GRW) for reviewing and commenting on drafts of the
letter. We appreciate member feedback and discussion as state
policymakers consider provider network and directory requirements which
could be a growing trend.

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