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Carriers urge DFR to report at provider-network level to avoid duplicate plan filings
Summary
At a Senate Bill 822 advisory meeting, carriers told department staff the draft reporting template’s plan-level granularity will produce duplicate submissions for large-group markets and urged a provider-network-level rollup to give a clearer picture of access across products and reduce administrative burden.
DFR policy analyst Brooke Hall presented the proposed Excel reporting template meant to capture quantitative network adequacy data required under Senate Bill 822. Multiple carriers said the current plan-level fields (health benefit plan name and plan number) will force insurers to submit many duplicate files for a single underlying provider network.
Marlene Converse of Kaiser Permanente said reporting “at the provider network level … would give [us] more a picture about how many patients are actually going to be potentially using those providers in the network” rather than filing separate spreadsheets for each product and plan. Antoinette (Cambia) and Gary (PacificSource) echoed that large group markets use master policy numbers and that rolling up to network level would simplify reporting and DFR review.
DFR staff acknowledged the concern and said the rule currently requires plan-level reporting but that the department will explore whether provider-network-level reporting is a better metric and may follow up with carriers after the meeting. Spencer Peacock (CFR) said analysts will work with carriers to determine an appropriate unique identifier if the rule retains plan-level fields.
Brooke asked carriers to provide feedback on the template by November 17 and requested rule comments by the 28th so staff can incorporate changes before the next RAC meeting. The department signaled it will consider a hybrid approach if some data elements cannot be collected in 2026.
