Regulatory Health Link Division Meeting Agenda and Updates December 16, 2024

10:00 am-11:30 am Central December 16, 2024 Regulatory Health Link Division, Arkansas Insurance Dept., Dept. of Commerce 1

Agenda 1)Introductions & housekeeping. 2)Recap. 3)Timeline Overview. 4)Significant Operational Changes. 5)PTNP significance will be felt earlier. 6)Limitation of 10 provider locations. 7)Address quality validation process. 8)Justification template. 9)Reviewing PTNP changes. 10)Questions. 2

Agenda 1)Introductions & housekeeping. 2)Recap. 3)Timeline Overview. 4)Significant Operational Changes. 5)PTNP significance will be felt earlier. 6)Limitation of 10 provider locations. 7)Address quality validation process. 8)Justification template. 9)Reviewing PTNP changes. 10)Questions. 3

Recap. CMS-CCIIO NA Time and Distance standards applicable PY2026 AID decided to have one NA standard in the state thereby CMS- CCIIO NA Time and distance standards becomes applicable starting PY2026. Rule 106 will be amended as the Department works the kinks in the implementation With no Federal guidance on data governance for common understanding of provider classifications, the Department decided to keep it s industry-collaborative data governance process running, but with entirely new data. Change from the existing Arkansas provider types to CMS-CCIIO provider-types with different definitions has created challenges and demands on the regulator-industry collaborative for common understanding of provider classifications. 4

Agenda 1)Introductions & housekeeping. 2)Recap. 3)Timeline Overview. 4)Significant Operational Changes. 5)PTNP significance will be felt earlier. 6)Limitation of 10 provider locations. 7)Address quality validation process. 8)Justification template. 9)Reviewing PTNP changes. 10)Questions. 5

Timeline PTNP rounds & certification review We are here We have just completed this round Last round before we go live with CCIIO T&D stds Certification Review for PY2026 PTNP Round 2 of 2024 PTNP Round 1 of 2025 mid-Aug, 2024 mid-March, 2025 mid-May, 2025 mid-Dec, 2024 Jan 1, 2026

PTNP Round 1 of 2025 (Second cut of Federal Requirements) Issuers & AID meet Stage 1 (Issuers suggesting changes) 16 days Stage 2 (Issuers voting) 14 days 30 days 28 days 2/28/2025 Votes from Issuers 1/31/2025 Consolidated suggestions by AID 3/14/2025 Finalized PTNP by AID 1/15/2025 Add/Delete Suggestions from Issuer 12/16/2024- Initial template published 7

Agenda 1)Introductions & housekeeping. 2)Recap. 3)Timeline Overview. 4)Significant Operational Changes. 5)PTNP significance will be felt earlier. 6)Limitation of 10 provider locations. 7)Address quality validation process. 8)Justification template. 9)Reviewing PTNP changes. 10)Questions. 8

Arkansas Network Adequacy Regulation HOW IT ALL WORKS HOW IT ALL WORKS TOGETHER TOGETHER 9

Before PY2026 AR Specialty Access Template (County Level-Provider Type Statistics Reported by Issuer) NA Template (Detailed Data. NPI & Practicing locations) AR Supplemental NA Template (Template to hold provider data for provider types CCIIO would disallow but needed by Arkansas) Network ID Template (Identifies unique networks used by issuer.) AR Provider-Enrollee Ratio Template (State Level Provider-Enrollee ratios for various provider types) AR Justification Template (Justifications for shortcomings on county level statistics for different provider types) Service Area Template (Describes service area(s) covered by plans) Seven data templates used for Network Adequacy Regulation in Arkansas 10

AR Specialty Access Template (County Level-Provider Type Statistics Reported by Issuer) NA Template (Detailed Data. NPI & Practicing locations) AR Supplemental NA Template (Template to hold provider data for provider types CCIIO would disallow but needed by Arkansas) Network ID Template (Identifies unique networks used by issuer.) AR Provider-Enrollee Ratio Template (State Level Provider-Enrollee ratios for various provider types) AR Justification Template (Justifications for shortcomings on county level statistics for different provider types) Service Area Template (Describes service area(s) covered by plans) Seven data templates used for Network Adequacy Regulation in Arkansas A combination of Federal and Arkansas state maintained templates used. 11

from PY2026 AR Specialty Access Template (County Level-Provider Type Statistics Reported by Issuer) NA Template (Detailed Data. NPI & Practicing locations) AR Supplemental NA Template (Template to hold provider data for provider types CCIIO would disallow but needed by Arkansas) Network ID Template (Identifies unique networks used by issuer.) AR Provider-Enrollee Ratio Template (State Level Provider-Enrollee ratios for various provider types) AR Justification Template (Justifications for shortcomings on county level statistics for different provider types) Service Area Template (Describes service area(s) covered by plans) Five templates, not seven, required during data submission time from PY2026. 12

from PY2026 Current Finalized Provider Type NPI Pool (PTNP) (Provider classifications vetted by the industry) NA Template (Detailed Data. NPI & Practicing locations) Provider location (Not provider classification) Provider classification Consumer location QHP Sample Population file (Provided by CCIIO.) CCIIO requirement CCIIO NA Drive Distance for each Provider Type & Medicare County type AID s Computation of coverage % Network Shortcomings AR Justification Template (Justifications for shortcomings on county level statistics for different provider types) AID is not requesting for NA computed results from issuers as the Department will calculate it starting PY2026. Use of PTNP classification data has moved ahead in the regulation process. It is used by AID in the adequacy computation stage rather than later in the analysis stage. 13

compliance dialogs related to PTNP -bubbles up sooner Use of PTNP classification data has moved ahead in the regulation process. Baxter County has shortcoming for OB-GYNs. We missed adding some participating OB-GYNs in the PTNP Insurance Company X Incorrect classification used by other issuers. Will correct in next PTNP round. Compliance Officer Insurance Company Y PTNP Data maintenance issues Building our network. Seeking OB-GYN s in the area. Insurance Company Z 14

from PY2026 Current Finalized Provider Type NPI Pool (PTNP) (Provider classifications vetted by the industry) NA Template (Detailed Data. NPI & Practicing locations) Provider location Provider classification Consumer location QHP Sample Population file (Provided by CCIIO.) CCIIO requirement CCIIO NA Drive Distance for each Provider Type & Medicare County type AID s Computation of coverage % Network Shortcomings AR Justification Template (Justifications for shortcomings on county level statistics for different provider types) 15

from PY2026 NA Template (Detailed Data. NPI & Practicing locations) CCIIO Template. Restricts number of practicing addresses per NPI to a max of 10. NPI with over 10 valid locations need some preprocessing by the issuer. Provider location AID s Computation of coverage % Network Shortcomings AR Justification Template (Justifications for shortcomings on county level statistics for different provider types) 16

Map below shows practicing locations of a plastic surgeon, with a total of 16 locations, denoted by orange and blue dots. Locations in blue had been reported to AID using the NA template, and the locations in orange have not been reported. Reporting one address instead of seven closely located addresses from the Little Rock would have enabled reporting of the six addresses missed out (in orange). NPI PROVIDER_NAME StandardAddress 1013924752 Yuen James C 1013924752 Yuen James C 1013924752 Yuen James C 1013924752 Yuen James C 1013924752 Yuen James C 1013924752 Yuen James C 1013924752 Yuen James C 1013924752 Yuen James C 1013924752 Yuen James C 1013924752 Yuen James C 1013924752 Yuen James C 1013924752 Yuen James C 1013924752 Yuen James C 1013924752 Yuen James C 1013924752 Yuen James C 1013924752 Yuen James C CITY Pine Bluff Warren Magnolia Morrilton Newport Maumelle Little Rock Little Rock Little Rock Little Rock Little Rock Little Rock Pocahontas Mountain View Springdale Fort Smith ZIP 3450 W 34th Ave 206 Bragg St 301 W Calhoun 411 Lentz Rd 221 Lindley Ln 102 Towne Centre Dr 1 Childrens Way 1 Childrens Way 10815 Colonel Glenn Rd 333 Executive Ct 4301 W Markham St 16101 Cantrell Rd 410 Camp Rd 1810 Ozarka College Dr 2601 Gene George Blvd 6601 Phoenix Ave 716035508 716712500 717533508 721103740 721124954 721137756 722023500 722023500 722048011 722054550 722057101 722234578 724551487 725606455 727620845 729035092 17

Providers with over 10 practicing locations CCIIO disallows over 10 practicing locations per provider in their NA template to curb runaway reporting of provider locations. Issuers are advised to preprocess data for providers with over 10 locations. The addresses of such NPIs reported to the Department will need to be judiciously spread-out avoiding reporting too many closely located addresses. 18

Practicing address data quality improvement a) AID expects health carriers to verify practice addresses at least once every ninety (90) days in accordance with requirements of federal law, and the practice addresses reported to the Department during plan review should reflect the latest round of such verification and correction. AID intends to implement a process by which certain addresses may be sent back to the issuer for review in the early stages of review by the Department. The Department believes that a small fraction of all the reported practicing locations are competitively advantageous to an issuer. If reported incorrectly however, such locations can cause problems for all stakeholders- all other issuers and to the regulator. Other issuers may have to deal with an objection based on inaccurate address information by a competitor. Such situations usually leads to a lot of back-and-forth dialog till the address is discovered to be incorrect. Therefore competitive locations of scarce providers need better scrutiny. Later, after completing the address review described in b) above, if a competitive provider address is found to have generated incorrect objections for other issuers, an inquiry by the Department could be triggered to review shortcomings surrounding processes around a) above. Besides avoiding the inefficiencies described in c) above, the address quality would inform the Department better, on insights as to where improvement is truly possible and where it is not. That in turn is crucial for Department s ability to issue objections only when the possibility of improvement exists. The Department s belief that competitive addresses are a small fraction of all the reported practicing locations has not yet been quantified and that is important for feasibility of this effort/process. Rule 106 would be amended according to the feasibility of this effort/process. Competitive address have certain uncommon combination of characteristics a) Provider type is scarce, and b) Provider location reported by only one issuer for an NPI, and c) No other issuer reports a location in the neighborhood of that reported in b) for the same NPI, or d) No other issuer reports a location in the neighborhood of that reported in b) for any other NPI of the same provider type. b) c) d) e) 19

Justification Template and closely mimics their template. The idea for customized NA justification template has been borrowed from CCIIO customized NA justification template for the issuer, depending upon the deficiencies. The customized spreadsheet within this template lists coverage percentage for every provider type-County that falls below the required 90% coverage. If AID finds deficiencies in the issuers network, the Department will generate a Adequacy Data Submission Instructions located at https://rhld.insurance.arkansas.gov/Info/Public/Templates. For details on the template, please refer to pdf PY<NNNN> SERFF Network 20

Agenda 1)Introductions & housekeeping. 2)Recap. 3)Timeline Overview. 4)Operational Changes. 5)PTNP significance will be felt earlier. 6)Limitation of 10 provider locations. 7)Address quality validation process. 8)Justification template. 9)Reviewing PTNP changes. 10)Questions. 21

Timeline PTNP rounds & certification review We are here Last round before we go live with CCIIO T&D stds We are engaged in this round Certification Review for PY2026 PTNP Round 2 of 2024 PTNP Round 1 of 2025 mid-Aug, 2024 mid-March, 2025 mid-May, 2025 mid-Dec, 2024 Jan 1, 2026

PTNP Round 1 of 2025 (Second cut of Federal Requirements) Issuers & AID meet Stage 1 (Issuers suggesting changes) 16 days Stage 2 (Issuers voting) 14 days 30 days 28 days 2/28/2025 Votes from Issuers 1/31/2025 Consolidated suggestions by AID 3/14/2025 Finalized PTNP by AID 1/15/2025 Add/Delete Suggestions from Issuer 12/16/2024- Initial template published 23

Everything published and ready Finalized PTNP Initial Template 24

PTNP Size Changes Last data maintenance round resulted in 15.4% reduction. Now the CCIIO defined PTNP is only 8.1% larger than AIDs prior PTNP, despite almost doubling Provider Types to monitor. 25

Criteria Description NPI Count before PTNP Round Count after PTNP Round Change Percent change F001 Acute Inpatient Hospitals 178 142 -36 -20.2% F002 F003 F004 F005 F006 Cardiac Catheterization Services Cardiac Surgery Program Critical Care Services Diagnostic Radiology Inpatient or Residential Behavioral Health Facility Services Mammography Outpatient Infusion/Chemotherapy Skilled Nursing Facilities Surgical Services Urgent Care Allergy and Immunology Cardiology Cardiothoracic Surgery Chiropractor Dental Dermatology Emergency Medicine Endocrinology ENT/Otolaryngology Gastroenterology General Surgery Gynecology, OB/GYN Infectious Diseases Nephrology Neurology Neurosurgery Occupational Therapy Oncology - Medical, Surgical Oncology - Radiation Ophthalmology Orthopedic Surgery Outpatient Clinical Behavioral Health Physical Medicine and Rehabilitation Physical Therapy Plastic Surgery Podiatry 130 124 166 343 208 97 92 -33 -32 -36 -90 -29 -25.4% -25.8% -21.7% -26.2% -13.9% 130 253 179 CCIIO says max 59 Acute Care Hospitals for PY2025 in NA FAQs F007 F008 F009 F010 F011 P012 P013 P014 P015 P016 P017 P018 P019 P020 P021 P022 P023 P024 P025 P026 P027 P028 P029 P030 P031 P032 P033 P034 P035 P036 P037 P038 P039 P040 P041 P042 P043 P044 P045 152 209 440 419 261 81 723 153 659 1797 184 2433 141 196 289 784 839 136 251 554 192 1468 481 210 712 552 6905 136 2361 131 165 11404 1057 646 306 103 2001 216 160 120 160 321 336 233 73 619 117 535 1470 171 1888 113 153 240 648 613 113 210 458 163 1342 399 174 665 456 6128 123 2014 -32 -49 -119 -83 -28 -21.1% -23.4% -27.0% -19.8% -10.7% -9.9% -14.4% -23.5% -18.8% -18.2% -7.1% -22.4% -19.9% -21.9% -17.0% -17.3% -26.9% -16.9% -16.3% -17.3% -15.1% -8.6% -17.0% -17.1% -6.6% -17.4% -11.3% -9.6% -14.7% -29.8% -13.3% -14.2% -21.9% -19.3% -16.7% -14.6% -7.5% -18.1% -66.3% -8 -104 -36 -124 -327 -13 -545 -28 -43 -49 -136 -226 -23 -41 -96 -29 -126 -82 -36 -47 -96 -777 -13 -347 -39 -22 -1616 -231 -125 -51 -15 -151 -39 -106 92 143 9788 826 521 255 Primary Care Adult Primary Care Pediatric Psychiatry Pulmonology Rheumatology Speech Therapy Urology Vascular Surgery 88 1850 177 26 54

Type Individual Individual Category Primary Care Adult Primary Care Pediatric Inpatient or Residential Behavioral Health Facility Services Skilled Nursing Facilities Cardiology Gynecology, OB/GYN C090 Pulmonology Endocrinology Acute Inpatient Hospitals Rheumatology Ophthalmology Urology Rule106Criteria Rule106Count CMSCriteria C010 9140 C020 7703 CMSCount 9788 826 P038 P039 Facility C030 162 F006 179 Facility C070 582 F009 321 Individual Individual Individual Individual Facility C080 633 935 286 138 220 P013 P023 P041 P019 F001 619 613 255 113 142 C100 C110 C180 Individual Individual Individual C220 C230 C240 107 1073 223 P042 P031 P044 88 665 177 TaxonomyCode 207QA0000X 207RA0000X 208000000X 2080A0000X 2080N0001X Classification Family Medicine Internal Medicine Pediatrics Pediatrics Pediatrics Specialization Adolescent Medicine Adolescent Medicine Adolescent Medicine Neonatal-Perinatal Medicine Neonatal Pediatrics Perinatal Included In C020 C020 C020,P039 C020,P039 C020 363LN0000X 363LP0200X 363LP1700X 364SN0000X 364SP0200X 364SP1700X Nurse Practitioner Nurse Practitioner Nurse Practitioner Clinical Nurse Specialist Neonatal Clinical Nurse Specialist Pediatrics Clinical Nurse Specialist Perinatal C020 C020 C020 C020 C020 C020 27

Besides taxonomic definitions pay attention to CCIIO notes on Provider Types 28

Discussions & Questions Discussions & Questions Email RHLD.DataOversight@arkansas.gov 29