New Anthem Subcontractor Network Certification (SNC) Alternative Access Standard (AAS) Policy

Alternative access standards issued to participating medical groups

As part of DHCS APL 23-006 Delegation and Subcontractor Network Certification (SNC), Anthem Blue Cross (Anthem) is now granting alternative access standards (AAS) to participating medical groups (PMGs). The initial AAS are being provisionally granted on a one-time basis on April 15, 2023. After that, Anthem will issue AAS every three years, or in the case of SNC submission, or new group implementation.

Anthem will be provisionally awarding AAS to PMGs where DHCS has granted Anthem an AAS, and the PMG is non-compliant with time or distance standards on a one-time basis on April 15, 2023. The provisional AAS will be based on the time and distance of nearest contracted provider — and under the condition that the PMG will make good faith efforts to fill the gap in their network with expanded contracting efforts.

Anthem will conduct an analysis of the PMG’s service area to identify instances of noncompliance with DHCS time or distance standards by ZIP code, provider type, and population served. Anthem will notify the PMG of the instance(s) of non-compliance and our AAS process. If the PMG cannot commit to bring themselves into compliance with expanded contracting efforts, then they must request an AAS to avoid enforcement activity. PMGs must submit AAS requests for the entire network every three years. The AAS submission every three years does not preclude the PMG from submitting any significant changes to their network since the previous reporting year.

To request AAS, the PMG must provide documentation showing a good faith effort to contract with

out-of-network providers who would bring them into compliance. The PMG must then conduct an analysis to determine the time and distance of the next closest provider in Anthem’s network to use as the AAS. If the PMG needs assistance with this analysis, Anthem will provide resources and assistance as necessary.

Anthem will conduct geomapping to monitor gaps in our subcontracted networks on a monthly basis and in the case of provider termination. Anthem will also reach out to groups on a quarterly basis to monitor their good faith contracting efforts. Letters of Agreement will not count towards network adequacy but may be used for remediation efforts.