HHS Office of Inspector General 2015 Workplan Includes Review of Network Adequacy

The Department of Health and Human Services Office of Inspector General recently released its 2015 Work Plan.  This document sets forth OIG’s oversight and enforcement priorities for 2015.  That document specifically mentions that OIG’s work in 2015 will include review of network adequacy.  OIG “will review Medicaid managed care provider networks and describe the extent to which managed care beneficiaries have access to services.”  2015 Work Plan at 42 (the entire document is available here).  “In establishing and maintaining this network, managed care plans must consider the anticipated Medicaid enrollment, the expected use of services, the number and types of providers accepting new patients, and the locations of providers and beneficiaries.”  Id.

In other words, network adequacy will be very much in the spotlight in the year ahead.

Providers of behavioral health services and substance abuse services should keep this in mind.  All too often, providers are concerned that if they speak up about health plans and insurers that violate MHPAEA, they will jeopardize important business relationships with health plans and insurers.  But tens of millions of new Medicaid managed care beneficiaries are coming online, at the exact same time that the adequacy of provider networks is coming under increasing scrutiny.  Health plans and insurers need their existing provider networks more than ever, and established, clinically grounded treatment programs are hard to replace.

Providers have more power than they might think, and should keep this in mind when they make decisions about what role they are going to play in MHPAEA enforcement.