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Advocates: behavioral-health adequacy needs provider counts and trend data

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

Behavioral-health stakeholders at the RAC urged the department to collect provider-to-enrollee ratios and trend information to assess network adequacy for behavioral health, and suggested carriers add context to provider survey questions to improve response rates.

Melissa Todd, a psychologist speaking for OIMHP, told the committee that behavioral-health network adequacy requires a focus on provider numbers relative to members and on trends over time to make sense of any new data collection. She said insurers tend to carry adequate medical networks but have historically struggled with behavioral health network sufficiency.

"We really think that the focus needs to be on looking at the overall numbers of behavioral health providers in relation to members, and that we could make some comparisons between behavioral health and medical," Melissa said, suggesting the reporting template include questions and context that encourage provider cooperation.

DFR staff acknowledged some behavioral-health reporting elements are likely to be difficult for carriers and said they will consider which elements can be collected in 2026 and which may be delayed until 2027. Carriers asked for clarity on the level of granularity for behavioral-health reporting and whether expected enrollee counts or snapshots would be used for metrics.

Brooke Hall said the department will examine which reporting elements are feasible for the initial reporting year and may use a hybrid reporting format in 2026 if needed.