Dear Dr. Levine:

Community Care Network of Virginia, Inc. (CCNV) is the Commonwealth of Virginia’s only health center controlled network and has served in this role for twenty years. CCNV is in strong support of the Medical Society of Virginia’s public petition for amendment of the provider credentialing and recredentialing regulations found at 12VAC5-408-170 published in the Virginia Register of Regulations on February 8, 2016.

Virginia’s health centers provide care to the medically underserved as well as MCHIP enrollees throughout the Commonwealth. Last year’s data on health center patients reveals that while approximately 40% of the patients were uninsured and 35% were recipients of publicly insured programs such as Medicaid/Medicare, almost a quarter of health center patients are MCHIP enrollees. Virginia’s health centers provided care for 330,000 Virginia residents.

CCNV has many responsibilities that it fulfills on behalf of its network members and one of them is to perform credentialing related activities. Annually, CCNV performs credentialing/recredentialing services for over 350 providers. CCNV’s credentialing and recredentialing activities assure its patients have access to the same high level of quality providers that all residents in the Commonwealth enjoy. CCNV applauds the language in the Certificate of Quality Assurance of Managed Health Care Health Insurance Plan (MCHIP) Licensee regulations found at 12VAC5-408-170 that assure provider quality through the credentialing process. I am familiar with the regulations as I drafted them while they were in their nascent stage. As evidence of my familiarity with the regulations, I invite you to review an article I wrote about them that was published in the Virginia State Bar’s Health Law Section newsletter entitled, “Inside the MCHIP Regulatory Process”. The article can be accessed at https://www.vsb.org/sections/hl/HLN-2001-2.pdf.

CCNV has reviewed the Medical Society of Virginia’s proposed changes in the regulations in great detail. CCNV concurs with each suggested change as they promote the ability for quality network providers to begin caring for patients in Virginia with all deliberate speed. The ability to have providers begin to see patients at the time they are credentialed assures true network adequacy. Network adequacy is severely compromised if the MCHIPS are able to identify providers in certain geographic areas who are on the MCHIP list as being credentialed but are not able to care for patients because the providers have not been officially “enrolled” into the MCHIP automated system. The amount of time it takes to have providers enrolled in MCHIP automated systems often prevents certain geographic areas, particularly rural areas, from benefitting from having an adequate number of providers to care for the enrollees who are paying for the MCHIP products.

In closing, CCNV strongly concurs with the changes proposed by the Medical Society of Virginia and encourages the proposed amendment as identified. Please feel free to contact me if you have any questions.

Sincerely,

Rene S. Cabral-Daniels, JD, MPH

CEO, Community Care Network of Virginia, Inc.

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