Episode: Navigating Texas Network Adequacy Requirements

Navigating Texas Network Adequacy Requirements

Nov 11· The Totally Adequate Podcast

Guests:

Zach Snyder, JD, MPA, VP Government Affairs, Quest Analytics | Connect on LinkedIn

Stephanie Stephens, Former Texas Regulator, Stephens Consulting, LLC

Host: April Beane, VP of Marketing, Quest Analytics | Connect on LinkedIn

About this Episode

Texas has introduced some of the most stringent network adequacy requirements in the country, reshaping how health plans design, monitor, and report on provider networks. Join expert Stephanie Stephens, a former Texas regulator, as she sits down with the Quest Analytics team to unpack HB 3359, explore compliance best practices, and look forward to national trends and the changing landscape to evaluate network access, network adequacy, and provider directory accuracy.

Key Takeaways

1. Data Accuracy Is Becoming a Measurable Compliance Expectation

Emerging policy initiatives across federal and state agencies are introducing measurable benchmarks for provider data accuracy and network adequacy. According to Snyder, “In 2025, and the year isn’t even over yet, we’ve already identified over 70 policy initiatives related to network adequacy across the country. More than 20 have become law, and Texas is no exception.”

With federal actions like CMS’s Medicare Advantage 2026 Final Rule and the proposed Requiring Enhanced and Accurate Lists of Health Providers Act (REAL Health Providers Act), health plans are facing new expectations for public accountability. Requirements such as annual provider data submissions and public accuracy scoring underscore the need for health plans to maintain transparent and reliable data.

2. Automation Replacing Manual Attestations

Another trend is the shift from manual attestations by health plans toward automated systems and direct validation. This transition aims to address inefficiencies, reduce administrative burdens, and promote innovative approaches to data management and oversight. Federal initiatives like the National Directory of Healthcare (NDH) pilot push for direct provider validation within the Exchange program. Broader federal priorities, including Transparency and Interoperability, are promoting alignment across multiple federal regulatory systems.

3. Collaboration Between Health Plans and Regulators

Effective collaboration between health plans and regulators is increasingly fundamental to improved alignment and streamlined compliance. Stephens emphasized that transparency fosters productive dialogue between these stakeholders, stating, “There’s an opportunity for more transparency on both sides — regulators and health plans — working together to develop the right standards.”

4. Role of Technology For Oversight and Health Plans

Regulators are beginning to explore the potential of emerging technologies, such as artificial intelligence (AI), to streamline oversight and compliance processes. AI holds promise in processing large datasets and distilling actionable insights that benefit both regulators and health plans. Stephens emphasized this point, stating, “There has to be technology that is helping states and health plans make sense of the data — find the trends, find the issues, and pull those out and highlight them. It’s great to have data, but at the end of the day, it has to be actionable. I think that’s where the technology — and hopefully AI come in — making that data more actionable.”