March 30, 2021

Ms. Rebekah Allen

Senior Policy Analyst, VDH

9960 Maryland Drive

Suite 401

Richmond, VA 23233

Dear Ms. Allen:

The Virginia Association of Health Plans (VAHP), on behalf of our health plan members, appreciates the opportunity to offer the following comments on the Virginia Board of Health Regulation for the Certificate of Quality Assurance of Managed Care Health Insurance Licensees, 12VAC5-408-10 et seq.

Due to changes within the proposed regulation, particularly the deletion of Section F.3., Section D.6. should be removed. There should not be a mandated timeframe for completion of Credentialing if the provider can see members during the credentialing application period and can receive payment in arrears.

The statute states in 38.2-3407.10:1: A carrier that credentials physicians, mental health professionals, or other providers in its network shall establish reasonable protocols and procedures for reimbursing new provider applications, within 30 days of being credentialed by the carrier, for health care services or mental health services provided to covered persons during the period in which the applicant’s completed credentialing application is pending.

D. Policies for credentialing and recredentialing shall include:

6. A requirement that the MCHIP licensee notify the applicant within 60 calendar days of receipt of an application if information is missing or if there are other deficiencies in the application. The MCHIP licensee shall complete the credentialing process within 90 calendar days of the receipt of all such information requested by the MCHIP licensee or, if information is not requested from the applicant, within 120 calendar days of receipt of an application. The department may impose administrative sanctions upon an MCHIP licensee for failure to complete the credentialing process as provided herein if it finds that such failure occurs with such frequency as to constitute a general business practice.

The policies shall be made available to participating providers and applicants upon written request.

Because the law now allows a provider to treat our members during the credentialing process, then having a turn-around time on credentialing does not serve the same need and is inconsistent with the statute. We respectfully request that section D.6. to be removed.

Sincerely,

Doug Gray

Executive Director