Network Adequacy 
Filing Requirements

The information below is for health carriers seeking Provider Network Adequacy approval for plan year 2025. These requirements apply to any “health carrier” defined under Minnesota Statutes Chapter 62A.011, including insurance companies and health maintenance organizations (HMOs).

Deadline for Network Adequacy Submissions

Return network filings by May 22, 2025.

Regulatory Overview

The Chapter 62k Minnesota Health Plan Market Rules, outlined in Minnesota Statutes Chapter 62K, set forth the requirements applicable to individual and small group health plans offered, sold, issued, and/or renewed in Minnesota beginning January 1, 2015. Unless otherwise exempted from Minnesota Statutes Chapter 62K, the rules apply to all individual and small group health plans offered in Minnesota, either on or off Minnesota’s health insurance exchange.

All health carriers offering health plans that require an enrollee to use or that create incentives, including financial incentives, for an enrollee to use a designated provider network, must assure that providers in the designated network are geographically accessible to all potential enrollees within the health plan’s defined service area. All distinct networks offered, sold, issued, and/or renewed on or off Minnesota’s health insurance exchange must be submitted for approval. Provider networks must be structured so that maximum travel distance or time for an enrollee to the nearest primary care, mental health or general hospital services be the lesser of 30 miles or 30 minutes. The maximum travel distance or time for an enrollee to specialty physician services, ancillary services, specialized hospital services, or other types of services must be the lesser of 60 miles or 60 minutes.

Waiver Renewals:

The 2019 Minnesota Legislature amended Provider Network Adequacy waiver requirements under Minnesota Statutes 62K.10, Subd. 5.

For network adequacy waivers granted in plan year 2025 carriers must demonstrate steps taken to address network adequacy in that year, using the Request for Waiver form. Waiver renewal guidelines listed on the Request for Waiver form.

Health Systems Access Template Required for Individual Market Filings

Under Minnesota Statutes 62K.10, Subd. 1a, a health carrier that actively markets an individual health plan in a group of Minnesota counties must offer, in those same counties, at least one individual health plan with a provider network that includes in-network access to more than a single health care provider system. To document this, use the Health Systems Access Template. Locate the document through System for Electronic Rate and Form Filing (SERFF) on the Plan Management Supporting Documents tab. Submit this template in the Individual binder folder. Include all health care systems in the Provider File submitted to the Provider file.

Network adequacy data is nonpublic until the network is approved by the Minnesota Department of Health (MDH) and the corresponding rates are approved in the plan management binder within the System for Electronic Rate and Form Filing (SERFF). While MDH does not publish lists of providers, MDH may release this data after the public date and upon request. Provider network lists are not considered trade secret under Minn. Stat. 13.37.

Documents Required to Assess Network Adequacy

• Provider File (Excel)
• Geographic Access Maps
• Network Adequacy Attestation Document (Word)
• Request for Waiver (if needed) (Excel)
• Request for Waiver - ECP (if needed) (Excel)
• Network Service Area Partial County Justification (Word)

Submit all documents through CloudDrive. For assistance, please see the Network Adequacy Submission Instructions (PDF).

Essential Community Provider (ECP) Requirements for Provider Networks

Essential Community Providers (ECPs) required in all filings. This ensures that networks include a broad range of ECPs to serve the unique needs of Minnesota populations. Minnesota requirements are based on the ECP standards developed for Federally-facilitated Exchanges (FFEs). Consistent with these standards, issuers must include a minimum of 35% of the available Essential Community Providers (ECPs) located within a plan’s service area. The Provider Network Adequacy Submission Instructions and Model QHP Addendum (PDF) provide further guidance on these requirements.

Information Specific to Standalone Dental Network Filings – Limited-Scope Pediatric Dental Plans

Dental carriers that wish to be certified as Qualified Dental Plans (QDPs), also known as Stand Alone Dental Plans (SADPs), must submit networks for approval. Include a minimum of 35 percent  Dental ECPs located within the SADP’s service area. The Provider Network Adequacy Submission Instructions provide further guidance on these requirements.

For more information, email health.managedcare@state.mn.us.