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NAT Act Highlights


Your Chicago Medical Society was the catalyst for vital legislation drafted by the Illinois State Medical Society and now awaiting the governor’s signature.

The Network Adequacy and Transparency Act (the NAT Act) contains provisions set forth by a CMS taskforce, which in 2015 began investigating the emergence of narrow and tiered plans in Illinois. Once the CMS taskforce developed its response plan, a set of recommendations, they were submitted to ISMS for prompt action.

Following its analysis, ISMS incorporated the CMS provisions into its draft bill that was introduced in spring 2016. The ISMS-drafted legislation won overwhelming support from lawmakers, physicians, and patients.

Illinois' new NAT Act:
  • Provides the Illinois Department of Insurance a framework to ensure that patients have access (close proximity) to necessary health care professionals, including specialists and appropriate health care facilities.
  • Requires health plans to maintain up-to-date provider directories. Reliance on inaccurate provider directories was a concern voiced by physicians. Now, health insurance plans must notify patients in a timely fashion if a physician or hospital is dropped from a network, to help patients avoid surprise outof-network charges.
  • Obligates physicians to notify affected patients if they choose to leave a network as a result of nonrenewal or plan termination.
  • Requires in-network facilities to provide disclosures to patients advising them that some care may be delivered by out-of-network providers.
  • Prevents patient care disruptions due to changes in health insurance networks. A patient’s physician may be dropped from the network, but patients with complex conditions will be able to stay with their physician long enough to make a smooth transition at no additional cost.

Prior to the bill’s passing, ISMS and the Illinois Health and Hospital Association negotiated several amendments. One change allows network plans to consider the use of telemedicine to partially meet network adequacy requirements. Also, the departure of a physician or hospital provider from a network plan will not be considered a “qualifying event” that would allow the patient to change insurance plans. The bill also clarifies that network adequacy standards apply only to the lowest cost -sharing tiers provided in individual plans (not group plans). Finally, the “effective date” of the legislation, for all plans offered for coverage is on or after Jan. 1, 2019.

UPDATE: CMS Grassroots Working For You on the NAT Act

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