Per the CY 2023 Final Rule published on May 9, 2022, CMS requires applicants to demonstrate a sufficient network of contracted providers to care for beneficiaries before approving their application. Additionally, for CY 2024, CMS adopted regulations explicitly stating that applications may be denied if network adequacy criteria are not met.
For CY 2024 applications, plans that previously relied on a Letter of Intent (LOI) to meet network adequacy requirements must now convert the LOIs into fully compliant agreements. Plans must ensure that all providers are contracted and credentialed to meet the full network adequacy requirements starting from January 1 of the contract year.
The additional 10% credit previously applied for the CY 2024 application will no longer apply. This means plans need to contract and credential providers for these specialties by the end of 2023 to fulfill CMS CY 2024 network adequacy requirements.
Furthermore, for plans that use LOIs to meet adequacy requirements for new or expanding 2024 service areas, participation in the Triennial Review will be required during the first year of a plan’s operation in the new service area.
It’s expected that CMS will not allow LOIs or additional credits for CY 2025 applications. Therefore, plans that utilized LOIs in CY 2024, will need to complete additional work to finalize CY 2024 networks while simultaneously preparing for a Triennial audit and building CY 2025 provider networks. Networks must be fully compliant to submit applications for CY 2025 by February 2024.
Plans will need to juggle multiple work streams to ensure a fully compliant CY 2024 provider network and prepare for a CMS audit if applicable. Resources may be stretched further for plans that are also planning on CY 2025 applications.
ATTAC Consulting Group’s network strategy and contracting experts are ready to assist your plan to achieve your provider network goals. Our expert consultants can also provide assistance with Medicaid (including HCBS or LTSS programs), commercial, or Workers Compensation network development needs.
