A number of the “final” provisions included in the rule are critical to people with HIV infection, and it will be important for HHS to establish monitoring systems to ensure they are applied across states.
Of particular interest and concern to our members are the “network adequacy standards” including the inclusion of “essential community providers.” We strongly support the more robust requirements for network adequacy standards that require enrollees have timely access to all services and urge you to closely monitor for enrollee access to HIV providers and services. We also strongly support the explicit recognition that Ryan White grantees are considered “essential community providers” and also urge you to ensure that plans contract with the Ryan White-funded medical providers.
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