Appeals Process
Network Adequacy
Network adequacy refers to whether a plan's provider network has sufficient in-network providers to meet member demand without unreasonable delay. Under the 2024 MHPAEA Final Rule (subject to non-enforcement), network adequacy for MH/SUD must equal that for medical/surgical. Under the 2013 rule and several state laws (CA, OR, WA), inadequate MH networks are still an NQTL violation. Network inadequacy is frequently the root cause of out-of-network balance-billing and OON claim denials.
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