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Protocol 4: Validation of Network Adequacy Activities 5 and 6

Michelle Hoover

Created on April 28, 2023

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Protocol 4:Validation of Network Adequacy

Activities 5 and 6
Start
Protocol 4
Activity 5: Communicate Preliminary Findings to Each MCP

Activity 5: Communicate Preliminary Findings to Each MCP

  • In Activity 5, the EQRO shares preliminary network adequacy validation findings with the MCP, and correct omissions and errors if necessary.
  • The EQRO will prepare a preliminary report for each MCP.
Protocol 4
Activity 5: Communicate Preliminary Findings to Each MCP

Activity 5: Communicate Preliminary Findings to Each MCP

In the report, the EQRO should:

Provide validation ratings

Document findings

Identify areas of concern

Make suggestions for improvement

Protocol 4
Activity 6: Submit Findings to the State

Activity 6: Submit Findings to the State

  • After completing Activities 1 through 5, the EQRO should compile the results for each MCP into the annual EQR Technical Report.
Protocol 4
Activity 6: Submit Findings to the State

Activity 6: Submit Findings to the State

In the annual EQR Technical Report, the EQRO will provide its assessment of each MCP's ability to:

Use sound methods to assess the adequacy of their managed care networks

Produce accurate results to support MCP and state network monitoring efforts

Collect reliable and vaild network adequacy monitoring data

Protocol 4: Activity 3
Step 1: Review the MCP's ISCA

Activity 6: Submit Findings to the State

The EQRO’s technical report to the state should follow the state’s required format, and include the following elements

Element 1

Element 4

Element 5

Element 2

Element 3

Element 6

08

Protocol 4
Review of Protocol 4

Review of Protocol 4

Now that we have discussed the activities that are involved in Protocol 4, let's take a few minutes to review the material we have covered.

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Review of Protocol 4

To ensure provider networks are sufficient to provide timely and accessible care to Medicaid and CHIP beneficiaries across the continuum of services, states must develop and enforce network adequacy standards.

  • To ensure provider networks are sufficient to provide timely and accessible care to Medicaid and CHIP beneficiaries across the continuum of services, states must develop and enforce network adequacy standards.
Protocol 4
Review of Protocol 4

Review of Protocol 4: Quick Facts

Click on the pencil icon for some quick facts about Protocol 4

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Review of Protocol 4

Review of Protocol 4

The state could set different network adequacy standards for urban, rural, and frontier regions of the state.

States must set network adequacy standards for all geographic areas covered by by their MCP contracts

To ensure provider networks are sufficient to provide timely and accessible care to Medicaid and CHIP beneficiaries across the continuum of services, states must develop and enforce network adequacy standards.

These standards may vary by geographic area for the same provider type

Protocol 4
Review of Protocol 4

Review of Protocol 4

States must set quantitative network adequacy standards for provider types covered under their managed care contracts. Some examples include:

Minimum provider-to-enrollee ratios

Maximum wait times for an appointment

These standards may vary by geographic area for the same provider type

Maximum travel time or distance to providers

Hours of operation

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Review of Protocol 4

Other considerations include:

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Review of Protocol 4

  • Medicaid and CHIP MCPs must conduct various activities to assess the adequacy of their networks and must maintain provider and beneficiary data sets that allow monitoring of network adequacy.
  • States can determine the strategies used to assess network adequacy. These strategies will vary based on the quantitative standards set by the state.

Examples:

  • Geomapping to determine if provider networks meet time and distance standards
  • Calculation provider-to-patient ratios
  • Analyzing utilization data to identify gaps in access
  • Telephone surveys to validate provider directory information
Protocol 4
Review of Protocol 4

The 1, 2 and 3 of Protocol 4

There are three basic steps for EQROs completing Protocol 4. EQROs are required to:

Examples:

Validate the results submitted by the MCPs and generate a validation rating for each network adequacy indicator

  • Geomapping to determine if provider networks meet time and distance standards
  • Calculation provider-to-patient ratios
  • Analyzing utilization data to identify gaps in access
  • Telephone surveys to validate provider directory information

Validate the data and methods that MCPs use to assess the adequacy of their networks.

The EQRO will report the validation findings in the annual EQR technical report

Protocol 4
Review of Protocol 4

Protocol 4 Phases

Protocol 4 consists of three phases:

Reporting

Analysis

Planning

Examples:

  • Establish definitions for each network adequacy standard and indicator, considering factors such as how the state defines provider types and how standards vary by region
  • Review past EQR network adequacy validation reports to understand prior monitoring and validation approaches
  • Ensure the report follows the state’s required format and meets federal requirements
  • Identify recommendations from the previous year’s report, and discuss progress made based on information gathered during the validation process
  • Compare the MCP’s data from previous years to the most recent data to assess reliability, as major changes could reflect data quality issues
  • Assess if the MCP’s definitions and methods for calculating each network adequacy indicator align with the state’s expectations
Protocol 4
Review of Protocol 4

Protocol 4 Phases and Activities

There are six activites in Protocol 4, organized into the three phases:

Examples:

  • Activity 3: Review of Information Systems
  • Activity 4: Validate Network Adequacy Assessment Data, Methods and Results
  • Activity 5: Communicate Preliminary Findings to MCP
  • Activity 6: Submit Findings to the State
  • Activity 1: Define the Scope of the Validation
  • Activity 2: Identify Data Sources for Validation

Reporting

Planning

Analysis

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Review of Protocol 4

Activity 1 : Define the Scope of the Validation

In Activity 1, the EQRO will work with the state to obtain all of the information needed for the validation.

Examples:

Identify methods used by the state and MCPs to monitor network adequacy

Identify the state's network adequacy standards

Reporting

Planning

Establish an approach for network adequacy validation

Protocol 4
Review of Protocol 4

Activity 1: Define the Scope of the Validation

There are four steps for an EQRO to complete to meet the objectives for Activity 1

Examples:

Identify and define network adequacy indicators for validation

Step 2

Step 1

Identify methods used by the state and MCPs to monitor network adequacy

Obtain needed information from the state

Identify the state's network adequacy standards

Establish network adequacy validation activities and timeline

Planning

stablish an approach for network adequacy validation

Step 4

Step 3

Identify and define provider types

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Review of Protocol 4

Activity 1: Define the Scope of the Validation

What is the difference between network adequacy standards and indicators?

Examples:

Network Adequacy Standard

Network Adequacy Indicator

Identify methods used by the state and MCPs to monitor network adequacy

Identify the state's network adequacy standards

Step 1

A quantitative parameter that states establish to set expectations for contracted managed care plans’ provider networks

A metric used to measure adherence to network adequacy standards and to determine plan compliance with state network adequacy standards

Reporting

Planning

Example: All enrollees have access to a primary care provider (PCP) within 30 miles or 30 minutes of their home

Example: The proportion of enrollees who have access to a PCP within 30 miles or 30 minutes of their home

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Activity 1: Identify Network Adequacy Standards

Examples:

Identify the state's network adequacy standards

Step 1

Planning

Protocol 4
Review of Protocol 4

Activity 1: Identify Network Adequacy Indicators

Examples:

Identify the state's network adequacy standards

Step 1

Planning

Protocol 4
Review of Protocol 4

Protocol 4: Define the Scope of the Validation

Questions to define network adequacy indicators

Questions to define provider types:

Examples:

Identify the state's network adequacy standards

Which provider types does the state consider primary care providers?

Are travel times measured separately for private vehicles, public transit, or other means of transportation?

Step 1

Are there circumstances in which providers who primarily see adult patients count toward network adequacy standards for the pediatric population?

Should distance be measured “as the crow flies” or using driving distances?

Planning

Protocol 4
Review of Protocol 4

Activity 2: Identify Data Sources for Validation

In Activity 2, the EQRO identifies all data sources needed for the network adequacy validation

Examples:

Step 1

Identify data sources

Identify the state's network adequacy standards

Are travel times measured separately for private vehicles, public transit, or other means of transportation?

Step 1

Are there circumstances in which providers who primarily see adult patients count toward network adequacy standards for the pediatric population?

Should distance be measured “as the crow flies” or using driving distances?

Planning

Step 2

Answer additional questions about state sources

Protocol 4
Review of Protocol 4

Activity 2: Identify Data Sources for Validation

Examples of potential data sources

Example questions:

Examples:

Identify the state's network adequacy standards

  • Which variables are necessary for network adequacy validation?
    • Beneficiary datasets
    • Provider datasets
  • Does the state set standards for completeness and accuracy of the data
  • What challenges could the EQRO encounter in accessing and using the data?
  • Beneficiary enrollment files
  • Provider network data files/online provider directories
  • Claims and encounter data
  • Grievance and appeals data
  • Survey Data (CAHPS, National Core Indicators)
  • Primary data collected by the EQRO by telephone, mail or in-person visit

Step 1

Planning

Protocol 4
Review of Protocol 4

Activity 3: Review Information Systems Underlying Network Adequacy Monitoring

In Activity 3, the EQRO determines if the MCP's information systems are able to collect and report high quality network adequacy data

Examples:

Step 1

Assess processes for collecting data not addressed in the ISCA

Step 2

Review the MCP’s most recently completed ISCA

Identify the state's network adequacy standards

Are travel times measured separately for private vehicles, public transit, or other means of transportation?

Step 1

Are there circumstances in which providers who primarily see adult patients count toward network adequacy standards for the pediatric population?

Should distance be measured “as the crow flies” or using driving distances?

Planning

Step 3

Interview MCP or other personnel to clarify findings

Protocol 4
Review of Protocol 4

Activity 3: ISCA

The ISCA is a mandatory element for the validation of network adequacy

Examples:

  • If the MCP has completed an ISCA within the previous two years, the EQRO should review the findings
  • If the MCP has not conducted an ISCA within the previous two years, the EQRO must conduct one consistent with the processes discussed in Appendix A of the EQR protocols

Identify the state's network adequacy standards

Are travel times measured separately for private vehicles, public transit, or other means of transportation?

Step 1

Are there circumstances in which providers who primarily see adult patients count toward network adequacy standards for the pediatric population?

Should distance be measured “as the crow flies” or using driving distances?

Planning

Step 1

Protocol 4
Review of Protocol 4

Activity 4: Validate Network Adequacy Assessment Data, Methods, and Results

In Activity 4, the EQRO will validate the MCP's assessment of its network adequacy

Examples:

Step 1

Assess the reliability and validity of MCP network adequacy data

Assess the methods used by the MCP to assess network adequacy

Step 2

Identify the state's network adequacy standards

Are travel times measured separately for private vehicles, public transit, or other means of transportation?

Step 1

Are there circumstances in which providers who primarily see adult patients count toward network adequacy standards for the pediatric population?

Should distance be measured “as the crow flies” or using driving distances?

Planning

Step 3

Step 4

Validate network adequacy results submitted by the MCP

Summarize network adequacy validation findings

Protocol 4
Review of Protocol 4

Activity 4: Validate Network Adequacy Assessment Data, Methods, and Results

Examples:

High confidence

The EQRO summarizes all validation findings, and gives the MCP a validation rating and comments for each network adequacy indicator

Step 1

Moderate confidence

Low confidence

No confidence

Planning

Step 1

Could not be validated

Protocol 4
Review of Protocol 4

Activity 5: Communicate Preliminary Findings to Each MCP

In Activity 5, the EQRO shares preliminary network adequacy validation findings with each MCP. The EQRO should prepare a preliminary validation report for each MCP. The report should:

Examples:

Step 1

Document the EQRO's findings

Make suggestions for improvement

Provide validation ratings

Identify areas of concern

Planning

Step 1

Protocol 4
Review of Protocol 4

Activity 5: Communicate Preliminary Findings to Each MCP

Examples:

The MCP may provide documentation to correct errors and omissions in the preliminary report. As needed, the EQRO may discuss the documentation with each MCP.

Step 1

Planning

Step 1

Protocol 4
Review of Protocol 4

Activity 6: Submit Findings to the State

In Activity 6, the EQRO will compile the results for each MCP into the annual EQR Technical Report. In the report, the EQRO will assess each MCP's ability to:

Examples:

Step 1

Produce accurate results to support MCP and state network adequacy efforts

Use sound methods to assess the adequacy of its managed care networks

Collect reliable and valid network adequacy monitoring data

Planning

Step 1

Protocol 4
Review of Protocol 4

Activity 6: Submit Findings to the State

A list of the data and documentation validated by the EQRO

The EQRO's technical report to the state should include:

A description of the state’s network adequacy standards, and the network adequacy indicators that were validated for each MCP

Worksheets, tools, and other supporting documentation

Examples:

Step 1

Recommendations for improving the reliability and validity of each MCP’s process for monitoring network adequacy

Analyses and conclusions for each network adequacy validation activity for each MCP

Findings on the MCP’s information systems capabilities and data integration

A description of the EQRO’s validation activities

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Planning

Step 1

Knowledge Check
Knowledge Check
Knowledge Check
Knowledge Check
Knowledge Check
Knowledge Check
Protocol 4
Congratulations!

Congratulations!

You have completed Protocol 4!
  • Now you are ready to proceed to
Protocol 5: Validation of Encounter Data Reported by the Medicaid and CHIP Managed Care Plan.
  • If you have any questions or comments about this lesson please reach out to your Program Manager, Course Instructor or leave a message in the Chat Boards.

📌 Course Instructor: Michelle Hoover

📌 email: mhoover@qsource.org