Thursday, April 18, 2013

Essential Community Providers identified by AAIHS

Dear Indian Health Service/Tribal/Urban Indian Health Program Leaders:
 
The health insurance law, also known as the Affordable Care Act, directs qualified health plans offered on the Marketplaces in 2014 to include a sufficient number of essential community providers (ECPs) in their networks to provide access for low-income and medically underserved individuals. As defined in the statute and regulation, ECPs include providers described in section 340B of the PHS Act and section 1927(c)(1)(D)(i)(IV) of the Social Security Act and include Tribal and Urban Indian Health Programs.  QHPs are finalizing their networks in the next few months. This letter will provide you with related resources that I hope will be of use to you.
 
On March 26, CMS/CCIIO posted a list of ECPs to assist health insurance plan issuers in locating ECPs: http://cciio.cms.gov/programs/exchanges/qhp.html. This list is not exhaustive. For example, it does not include Federal IHS facilities that might otherwise qualify as ECPs under the regulatory standard. In addition, plan issuers will be permitted to write in ECPs not on the list.  If your Tribal or Urban Indian Health Program is not on the list, you should let issuers in your area know you are an ECP so that they have the opportunity to include you in their network.  

In collaboration with states, CMS will monitor Qualified Health Plans (QHPs) for network adequacy and ECP sufficiency.  At this time, health insurance issuers that wish to establish QHPs may be approaching you with offers to join their provider networks.  Whether or not you are currently engaged with private insurers, please be attentive to these discussions.  Many of the patients whom you serve will be eligible to purchase health insurance from these QHPs, and these plans will begin coverage on January 1, 2014.  It could be beneficial for these individuals to choose QHPs with networks that allow them the choice of maintaining continuity of care with their current practitioners.  CMS notes that contracted ECPs are subject to applicable issuer credentialing standards for network providers. 

In collaboration with the Indian Health Service, CMS developed a QHP Addendum for Indian Health Care Providers to facilitate issuers contracting with Tribes, Urban Indian Health programs and Indian Health Service (IHS) providers.  CMS strongly encourages issuers and providers to use this Addendum, but use of the Model QHP Addendum is optional.  The Addendum was developed through tribal consultation and the engagement of tribal and issuer input.  You may access a copy of the Addendum at http://cciio.cms.gov/programs/exchanges/qhp.html.  In addition, a list of the Indian health providers will be posted in the near future.

The health care law offers new opportunities for you to better serve your patients, and we encourage you to learn more about the law and your options. 

Electronic Resources:
 
·         CMS/CCIIO “non-exhaustive list” of ECPs to assist health insurance plan issuers in locating ECPs: http://cciio.cms.gov/programs/exchanges/qhp.html.
 
·         More information on the definition of ECP and health insurer requirements regarding ECPs, see CMS’ “Letter to Issuers on Federally-facilitated and State Partnership Exchanges,” available at http://www.cciio.cms.gov/resources/files/issuer-letter-3-1-2013.pdf.
 
·         Additional information is available on the CCIIO website at http://cciio.cms.gov/
 
You are encouraged to reach out to potential insurers in your local area regarding ACA requirements. Please provide your feedback on this ECP communication to myself or the Albuquerque Area Director, ADM Richie Grinnell, thank you.
 
 
Leonard Thomas, MD
ABQ Area CMO

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