CMS released its Medicaid Managed Care Final Rule regarding managed care in Medicaid and the Children's Health Insurance Program, which revises and expands federal rules governing contracting and payment of Medicaid managed care plans. The Final Rule includes provisions regarding "network adequacy standards" and advises states to contemplate telemedicine and other technological solutions to ensure beneficiaries have reasonable access to all necessary care in order to obtain reimbursements. Additionally, the National Association of Insurance Commissioners previously released its model legislation for health benefit plan network access and adequacy ("Model Act"). The Model Act is designed for use by state legislatures. Like the Medicaid Managed Care Final Rule, the Model Act establishes standards for network adequacy. In doing so, the Model Act recognizes telehealth as an acceptable means (among others) of achieving network adequacy. These developments demonstrate the increasing acceptance of telehealth in the mainstream healthcare delivery system and illustrate how telehealth may be used as an essential element of network development and adequacy.

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