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New York Network Filings now Submitted via the Provider Network Data System

Per instruction from the NY Department of Financial Services (“DFS”) beginning October 1, 2016 insurers, including stand-alone dental and vision insurers, can no longer submit their PPO networks to the New York Department of Financial Services (DFS) via SERFF and instead must submit their PPO Networks via New York’s Provider Network Data System (PNDS).

Insurers, non-profit corporations and HMO’s, municipal cooperative health benefit plans, and student health plans (collectively “insurers”) established or maintained per NY Ins. L § 1124 need to submit their networks for review by DFS. Initial submissions must be received no later than April 25, 2017.

Networks that have previously been determined adequate by the Department of Health (“DOH”) pursuant to standards in the Public Health Law are exempt from the April 25, 2017 initial submission; however, most networks, even those previously approved, must be submitted quarterly with the submission deadline depending on the type of network. Changes to networks must be submitted within 15 days of said change. Ancillary forms such as Provider Selection Criteria, Quality Assurance Procedures and Sample Provider Agreements will still be submitted via SERFF in an annual informational filing.

PNDS was implemented by the New York State Department of Health (NYS DOH) in December of 1996 to gather information about the provider and service networks contracted to health insurers operating in New York State. The primary purpose of PNDS is to collect the data needed to evaluate provider networks, including physicians, hospitals, labs, home health agencies, durable medical equipment providers, etc. for all health insurers in New York State. This data will be used for a network adequacy review by DFS and will also be made available through a public facing provider lookup tool. The NYS DOH will begin collecting data through this updated submission portal, gradually phasing out the current Health Commerce System, with full implementation in 2017.

Users may notice that PNDS has capabilities similar to that of major medical plan and benefit templates submitted via SERFF. The post-submission process varies from plan and benefit submissions in that the submitter must check PNDS for correspondence from the state. PNDS does not currently have a notification system; however, if an objection is received it can and must be addressed through the PNDS system. Another important difference from a SERFF submission is that the network filing is not correlated with the policy forms filing or the annual ancillary network forms filing at this time. Changes made to policy forms do not require PNDS notification.

To utilize PNDS insurers’ must create an account with at least two individuals from the company who will have account administrative abilities, dubbed Coordinators. The Coordinators will then be able to provide Plan Submitter accounts to those they wish to have the ability to test and submit their network data. Data is uploaded to the system via a New York PNDS CVS Excel file. The system has the ability to allow the submitter to validate the CVS file and respond to feedback from the system of any errors from giving the insurer the ability to correct the file prior to submission to New York.

MCR has gained expertise with this system and is ready to assist you in completing your New York network filing. We recommend that insurers submitting networks for the first time begin the submission process prior to the April deadline to allow time for account set up and CVS completion.

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