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Insurers warn secret-shopper sampling should guide wait-time reporting, not exhaustive provider calls

Rulemaking Advisory Committee for Senate Bill 822 (network adequacy) · October 22, 2025
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Summary

Moda Health and other carriers told DFR that appointment wait-time data should follow CMS's statistically valid sampling/secret-shopper approach; carriers said the template as written could be read to require calling many thousands of providers, a burdensome and unreliable method.

Scott White of Moda Health raised concerns that the reporting template as drafted could be interpreted to require contacting every provider in every county to collect appointment wait-time data — an approach he said is impractical and would not meaningfully improve validity. He recommended mirroring CMS methodology that provides calculations for statistically valid samples and then using secret-shopper surveys.

"If it's the expectation is we're calling tens of thousands of providers...that is an untenable request and is not giving you any real validity for any of this information," Scott said, urging DFR to adopt CMS sampling guidance rather than a census approach. Other carriers (PacificSource, Kaiser) echoed concerns about survey response rates and operational feasibility.

DFR staff responded that the department's intention is to use the CMS secret-shopper survey methodology and that the template may be adjusted (for example, separating appointment wait times into a distinct tab) to reflect sampling rather than a full-provider census. Staff asked carriers to share CMS guidance and publicly available calculations so DFR can align its reporting requirements.