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Second Opinion

Learn about policy issues important to medical schools and teaching hospitals, with Executive Vice President Atul Grover, M.D., Ph.D.

Washington Highlights

HHS Releases Database of Essential Community Providers

March 29, 2013—The Department of Health and Human Service (HHS) March 26 released a database of available essential community providers (ECPs) to assist insurance issuers offering products on the Affordable Care Act’s health insurance marketplaces in complying with existing regulations and requirements outlined in the recent Centers for Medicare and Medicaid Services (CMS) “Letter to Issuers” on federally-facilitated and state partnership exchanges. AAMC March 15 submitted comments on this guidance explaining that CMS should set and enforce network adequacy and ECP standards that will protect funding for graduate medical education and access to teaching hospitals because of the unique and critical role these institutions serve in their communities [see Washington Highlights, March 22].

ECPs are providers who serve predominantly low-income, medically underserved individuals. The AAMC letter expressed the importance of including teaching hospitals as ECPs and ensuring that qualified health plans (QHPs) include at least one academic medical center in their provider networks to perform specialized services and lifesaving care that no other institutions can provide.

CMS previously established regulatory requirements for inclusion of ECPs in QHP provider networks.  ECPs include providers described in section 340B(a)(4) of the Public Health Service Act and section 1927(c)(1)(D)(i)(IV) of the Social Security Act.  The database of ECPs also includes providers that could otherwise qualify under the regulatory standard discussed in the Letter to Issuers.

In the Letter to Issuers, CMS proposed that to satisfy the safe harbor standard for inclusion of ECPs, QHP issuers must include at least one ECP in each ECP category in each county in the service area, if an ECP in that category is available.  One of the ECP categories is hospitals.  The “ECP Provider Types” CMS includes in this category are DSH and DSH-eligible hospitals, children’s hospitals, rural referral centers, sole community hospitals, free-standing cancer centers and critical access hospitals.

In a press release, HHS acknowledged that the database is not an exhaustive list.  HHS will not update the list before health insurance issuers submit applications for the 2014 coverage year. QHP issuers may include providers in their application that meet the regulatory standard, but do not appear in the database. For example, issuers may write in any providers that are currently eligible to participate in 340B programs that are not included in the database.

AAMC members can check the database to determine whether their institutions are included in the list.  HHS expects to monitor inclusion of ECPs in QHP provider networks over time, including providers that issuers write in, and will update this database in future years.

Questions about the database may be directed to essentialcommunityproviders@cms.hhs.gov.

Contact:

Allison M. Cohen, J.D., LL.M.
Senior Policy and Regulatory Specialist
Telephone: 202-862-6085
Email: acohen@aamc.org

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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.


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For More Information

Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806
Email: jkleinman@aamc.org