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Kaiser presses DFR on first reporting year and telemedicine caps
Summary
Kaiser Permanente asked for clarity on whether the first required reporting year will be 2027 if the regulation is effective 01/01/2026, and requested that DFR increase the percentage of telemedicine providers that count toward quantitative network adequacy standards.
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Marlene Converse of Kaiser Permanente said carriers need clarity on the first year of reporting and the timeline for implementing the reporting template. She requested confirmation that the initial reporting submission would not be due until 2027 if the regulation is not effective until 01/01/2026, and cautioned that carriers may lack time to implement new standards and collect baseline data.
Marlene also asked that DFR increase the allowable percentage of telemedicine providers that may be counted in quantitative network adequacy calculations, arguing telemedicine is a widely used option and should be reflected in network counts. Brooke Hall thanked Kaiser for the feedback and said staff will include a section in the draft addressing expectations where carriers identify a network access gap and will engage with carriers about telemedicine caps.
Brooke later said the department intends to codify federal standards as of 01/01/2025 in the rule text and will not automatically adopt future CMS changes without legislative action, though CMS guidance could inform department guidance on an annual basis.

