Massachusetts Medical Society: Comments to the Division of Insurance (DOI) on Improving Provider Network Information

Comments to the Division of Insurance (DOI) on Improving Provider Network Information

On behalf of the Mass Collaborative (Collaborative), a voluntary coalition of payers, providers and associations lead by the Massachusetts Health and Hospital Association (MHA), the Massachusetts Medical Society (MMS), the Massachusetts Association of Health Plans (MAHP) and Blue Cross Blue Shield of Massachusetts (BCBSMA), we appreciate the opportunity to offer comments to the Division of Insurance (DOI) regarding improving provider network information.  The Collaborative is focused on simplifying and improving healthcare administration by increasing transactional efficiency, eliminating waste, and promoting standardization across the industry.  

As a group representing both payers and providers, we have long recognized that creating and maintaining accurate, meaningful provider directories requires a partnership between health plans and provider organizations and a mutual commitment to education and standardization.  Since January 2018, the Collaborative has been working closely with payers, providers and consumer advocates to address the challenges inherent in the overall process and to develop a roadmap and implement processes for creating accurate, consumer-friendly provider directories. Our specific initiatives are detailed below:

Provider Directory Workgroup and Interim Solutions

In January 2018, the Collaborative convened a provider directory workgroup to begin to identify challenges, opportunities and best practices for both payers and providers.  Because unique issues arise with behavioral health network information, we also created a subgroup of behavioral health providers to work on the issues that were specific to this discipline.  As the DOI report observed, carriers should have information about which providers regularly treat certain age groups and behavioral health conditions. With input from behavioral health experts from both plans and provider groups, we were able to modify the Collaborative’s existing provider demographic change form (download here) to include a detailed section for behavioral health providers to specify the populations they treat, the modalities they work with, and any specialty areas such as eating disorders or post-traumatic stress disorders.  This will enable providers to report more detailed information about the services they provide, and health plans to provide their members and prospective members with detailed information about their behavioral health participating providers.

In addition to the behavioral health changes, the form was modified to include more information from all provider types that will assist health plans in having the most up to date and accurate information for their directories.  It is the Collaborative’s goal that the provider demographic change form only has to be completed once and can then be submitted to all of the plans with which a provider participates. The Collaborative will be working on an education program beginning this summer, focused on informing plans and providers of the existence of this form, and that this form should be completed anytime there is a non-contractual change – i.e. a change in address, name, phone number, panel/practice status, and area of specialization. The leading members of the Collaborative strongly support the use of the provider demographic information change form as a short-term solution to improving the exchange of information between plans and providers. 

Healthcare Administrative Solutions (HCAS) Electronic Process – Longer Term Solution

The Collaborative has also been supportive of work towards a centralized electronic solution for collecting provider directory data. HCAS, a nonprofit entity founded in 2005 by several Massachusetts health plans, issued an RFP this past winter seeking vendor proposals to develop a single provider directory electronic solution that could be used by all payers and providers, and is in the process of selecting a vendor.  BCBSMA has conducted a parallel process and has been in discussions with HCAS regarding alignment.  HCAS will be working with provider organizations, both large and small, to ensure that the ultimate solution is one that works well across all users.  Once implemented, the expectation is that the vendor solution will provide a centralized process for providers to relay information to health plans. For providers, the importance of standardization cannot be overstated; an efficient, centralized process for provider directory data submission can help ensure submission of timely and accurate information from small and large provider organizations. 

Legislative Solutions

Finally, the Collaborative fully supports and was instrumental in crafting H.2947 “An Act to Increase Consumer Transparency about Insurance Provider Networks” sponsored by Representative Christine Barber.  The language in this bill was adopted as an amendment to HB4617 “An Act Establishing the Honorable Peter V. Kocot Act to Enhance Access to High Quality, Affordable and Transparent Healthcare in the Commonwealth.”  

This bill would establish a taskforce chaired by the DOI to make recommendations for improving the accuracy of provider directories  It also makes interim improvements that would ensure that in the short term, provider directories are easily accessible, searchable, and updated at least monthly.  The Collaborative worked closely with the Children’s Mental Health Coalition in developing this compromise language which holds all parties accountable while allowing health plans, providers and consumer advocates to continue to work together to develop a streamlined, sustainable long term solutions, such as the electronic solution that is being led by HCAS.


As we have heard from stakeholders across the industry, ensuring up-to-date provider directories is a complex task. Providers often move or add locations or change other demographic information without realizing the importance of notifying the health plans with whom they participate; health plans are not always timely in updating their directories when providers do submit this information.  Accurate provider directories must be the product of a partnership between the providers who must supply this data and the health plans who must ensure that their members have access to timely and accurate information about their networks.  It is also critical that any processes be administratively simple and standardized so that providers are not doing something different for every health plan. Representative Barber’s bill gives stakeholders the welcome opportunity to work with the Division to create interim and long term solutions that will give consumers access to timely and accurate information about each plan’s provider networks.

If you have any questions or would like more information about the Collaborative’s work in this area, please contact any of us at the addresses below.

Karen Granoff
Sr. Director, Managed Care 
Massachusetts Health and Hospital Association 

Michael Katzman
Director, Government & Regulatory Affairs
Blue Cross Blue Shield of Massachusetts

Elizabeth Leahy (
Public Policy and Research Manager
Massachusetts Association of Health Plans 

Yael Miller (
Director, Practice Solutions and Medical Economics
Massachusetts Medical Society


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