120.000 HEALTH INSURANCE COVERAGE

120.876        Guiding Principles for the Healthcare of Migrants

MSSNY will advocate for the development of adequate policies and/or legislation to address the healthcare needs of migrants and asylum seekers in cooperation with relevant legislators and stakeholders based on the following guiding principles, adapted from the High-level meeting of the Global Consultation on Migrant Health, i.e. the “Colombo Statement”.

MSSNY recognizes that migration status is a social determinant of health. and be it further

MSSNY affirms the importance of multi-sectoral coordination and inter-country engagement and partnership in enhancing the means of addressing health aspects of migration.

MSSNY recognizes that the enhancement of migrants’ health status relies on an equitable and non-discriminatory access to and coverage of health care and cross-border continuity of care at an affordable cost avoiding severe financial consequences for migrants, as well as for their families.

MSSNY recognizes that investment in migrant health provides positive dividends compared to public health costs due to exclusion and neglect, and therefore underscore the need for financing mechanisms that mobilize different sectors of society, innovation, identification and sharing of good practices in this regard.

MSSNY recognizes that the promotion of the physical and mental health of migrants as defined by the following select objectives from the World Health Organization’s 72nd World Health Assembly, Global action plan on promoting the health of refugees and migrants, 2019-2023, is accomplished by:

1. Ensuring that essential components, such as vaccination of children and adults and the provision of health promotion, disease prevention, timely diagnosis and treatment, rehabilitation and palliative services for acute, chronic and infectious diseases, injuries, mental and behavioral disorders, and sexual and reproductive health care for women, are addressed.
2. Improving the quality, acceptability, availability and accessibility of health care services, for instance by overcoming physical, financial, information, linguistic and other cultural barriers, with particular attention to services for chronic conditions and mental health, which are often inadequately addressed or followed up during the migration and displacement process, and by working to prevent occupational and work-related diseases and injuries among migrant workers and their families by improving the coverage, accessibility and quality of occupational and primary health care services and social protection systems.
3. Ensuring that the social determinants of migrants’ health are addressed through joint, coherent multisectoral actions in all public health policy responses, especially ensuring promotion of well-being for all at all ages, and facilitating orderly, safe, and responsible migration and mobility of people, including through implementation of planned and well-managed migration policies, as defined in the Sustainable Development Goals of the United Nations.
4. Ensuring that information and disaggregated data at global, regional and country levels are generated and that adequate, standardized, comparable records on the health of migrants are available to support policy-makers and decision-makers to develop more evidence-based policies, plans and interventions.
5. Providing accurate information and dispelling fears and misperceptions among migrant and host populations about the health impacts of migration and displacement on migrant populations and on the health of local communities and health systems.

A copy of this resolution will be transmitted to the AMA for consideration at its House of Delegates. (HOD 2024 – 172)

120.877        Full Transparency – Explanation of Benefits

MSSNY will advocate legislation and regulations that mandate that explanation of benefits, whether sent to the patient or the physician practice, include the actual CPT codes billed, DRG-codes, CPT descriptions, and optional consumer-friendly descriptions; and EOB must list the actual allowed amount, patient responsibilities (copay, deductible, coinsurance), non-covered and denied amounts with specific X12 reason codes in consumer-friendly explanations, what criteria is used for coverage and non-coverage, and includes detailed explanation on how to appeal, including contact information for plan administrator, applicable laws governing the plan benefits, and contact information to submit external complaints.

MSSNY advocates that AMA will advocate legislation and regulations that mandate that explanation of benefits, whether sent to the patient or the physician practice, including the actual CPT codes billed, DRG-codes, CPT descriptions, and optional consumer- friendly descriptions; and EOB must list the actual allowed amount, patient responsibilities (copay, deductible, coinsurance), non-covered and denied amounts with specific X12 reason codes in consumer-friendly explanations, what criteria is used for coverage and non-coverage, and includes detailed explanation on how to appeal, including contact information for plan administrator, applicable laws governing the plan benefits, and contact information to submit external complaints. (HOD 2024 – 266)

120.878        Transparency – Non-Payment for Services to Patients with ACA Exchange Plans with Unpaid Premiums

MSSNY will advocate for legislation to require that health plans inform healthcare providers whether the plan premium has been paid and whether the account is late on payment as part of benefit verification, whether by phone, fax, or electronic transaction, including but not limited to X12 270/271.

MSSNY will advocate that the AMA seeks legislation or regulation to require that health plans inform healthcare providers whether the plan premium has been paid and whether the account is late on payment as part of benefit verification, whether by phone, fax, electronic transaction including but not limited to X12 270/271.

MSSNY will advocate that the AMA seeks that X12 includes plan premium payment status as part of X12 270/271 standard transaction code updates.
That the AMA will report on the status of this resolution at the 2025 Annual Meeting. (HOD 2024 – 265)

120.879        Mandated Economic Escalators in Insurance Contracts

The Medical Society of the State of New York (MSSNY) will advocate through legislation or regulation for the mandatory insertion of an economic escalator provision in all commercial insurance contracts to account for economic inflation or a decline in Medicare Physician Fee Schedule (PFS).

MSSNY shall bring a similar resolution to the AMA to build a broader coalition advocating for the inclusion of economic escalators in insurance contracts across the US. (HOD 2024 – 260)

120.880        AI In Insurance Claims

MSSNY supports:(1) transparency standards which allow for the state agency auditing of AI algorithms used by New York State health insurers to approve and deny claims (2) the modification of New York statute to explicitly preempt the utilization of race and race-based proxies in the algorithmic claims processing of health insurance.

MSSNY advocates for the prohibition of the use of artificial intelligence in the denial of insurance claims.

MSSNY calls for a thorough examination and oversight of AI algorithms utilized in insurance claim processing to ensure fairness, transparency, and accountability.

MSSNY urges insurance companies to adopt policies that prioritize human review and intervention in the decision-making process for insurance claim denials.

MSSNY encourages collaboration with regulatory bodies, stakeholders, and experts in the field to establish guidelines for the ethical use of AI in insurance claim processing.

MSSNY shall communicate this resolution to relevant legislative bodies, regulatory agencies, and the public to promote awareness and action in addressing the ethical concerns associated with the use of AI in insurance claims.

MSSNY will create a task force that will further investigate the role and use of AI in health insurance plans. (HOD 2024, substitute in lieu of resolutions 256 and 257)

120.881        Do Not Penalize Primary Care Incentives if Patients Refuses Screening Tests

MSSNY and the AMA will lobby to propose legislation to the Department of Financial Services and Department of Labor (DOL) to cover fully and self-insured plans in order to revise the punitive practice that health insurances hold Physicians responsible for the sole actions of their patients. (HOD 2024 – 252)

120.882        Inappropriate Use of the Federal IDR Process

The Medical Society of the State of New York will work with the American Medical Association to ensure enforcement of state and federal laws that permit patients to consent to receive treatment from an out of network physician without it being deemed a surprise medical bill. (HOD 2024 – 61)

120.883        Outsourcing of Administrative and Clinical Work to Different Time Zones – An Issue of Equity, Diversity, and Inclusion

The Medical Society of the State of New York (MSSNY) will advocate that health plans that outsource their customer service facing operations to foreign countries in time zones separated by more than 4 hours from the US time zones should implement 16 or 24-hour availability for their support services staffed by outsourced employees to allow local day shift work schedules for their own outsourced employees in different time zones and provider employees located in similar time zones.

MSSNY will advocate that the American Medical Association supports the policy and advocates for national legislation that health plans that outsource their customer service facing operations to foreign countries in time zones separated by more than 4 hours from the US time zones should implement 16 or 24-hour availability for their support services staffed by outsourced employees to allow local day shift work schedules for their own outsourced employees in different time zones and provider employees located in similar time zones.

MSSNY will urge the American Medical Association to advocate for fair treatment of outsourced employees in vastly different time zones by health plans. (HOD 2023-265)

120.884           Prior Authorization – 24-Hour Maximum

MSSNY will advocate that all prior authorization requests and appeals of PA denials be resolved in accordance with the existing requirements for expedited decisions of 72 hours for non-urgent care and 24 hours for emergency care. (HOD 2023-105)

120.885           Restore NYSHIP IDR venue back to State Level

MSSNY will continue to advocate that out of network surprise medical bills resulting from care provided to patients insured by the New York State Health Insurance Plan (NYSHIP) should be adjudicated by the New York State Independent Dispute Resolution process. (HOD 2023-54)

120.886           Elimination of the Median in-Network Rate from Consideration at State Independent Dispute Resolution

MSSNY will advocate for (1) absolute clarity in how the median in-network rate is being calculated;  (2) a requirement that insurers provide the median in-network rate in their EOBs to out-of-network providers if they wish to use this rate as a consideration at IDR; and (3) a mechanism for providing the disputing physician with the raw data from which the insurer calculated the median in-network rate so they can independently confirm its accuracy.

MSSNY will also advocate for removing the median in-network rate as a required consideration for the New York State IDR process. (HOD 2023-53)

120.887           Advocating for a Prompt and Fair Federal IDR Process for Out-of-Network Disputes

MSSNY will advocate, and ask the AMA to advocate for, a prompt and fair federal IDR process that includes:

(1) timely processing of claims;

(2) directions to the IDR entity that no one data point is deemed in advance to be more important than any other consideration;

(3) direction to insurers only to use actual paid rates in consideration of the median contracted rate;

(4) directions to insurers not to consider data from other specialties in determining the median contracted rate;

(5) direction to insurers not to consider data from other self-funded plans in determining the median contracted rate;

(6) direction to insurers that they must present the median contracted rate to the physician in the EOB if they want to use this data point at IDR;

(7) direction to insurers to make all raw data available to the disputing physician from which the median contracted rate was calculated so the physician can ascertain whether the median contracted rate was calculated correctly;

(8) eliminating the non-refundable administrative fees for physicians to bring a claim to IDR;

(9) allowing physicians to batch similar claims;

(10) providing live help for phone calls from both federal regulating departments and the IDR entities to facilitate the timely processing of claims;

(11) requiring insurers to make payments within 30 days when they lose at IDR (as per the law). (HOD 2023-52)

(See also Abortion and Reproductive Rights, 5.000; Alcohol and Alcoholism, 20.000; Reimbursement, 265.000)

120.888           Concurrent Processing of Procedure Codes

The Medical Society of the State of New York (MSSNY) will advocate for legislation or other regulatory intervention to prohibit health insurers from making access to the state and federal independent dispute resolution more difficult by separately processing various codes related to out of network services. (HOD 2022-260; substitute resolution recommended and adopted by Council 1/26/23)

120.889           Abolish “Preferred” Status of Laboratories

The Medical Society will advocate for health insurers to have comprehensive networks for delivery of lab services that ensure meaningful choice for physicians and affordability and accessibility for patients. (HOD 2022-58)

120.890           We’re Mad as Hell and We aren’t Going to Take it Anymore

MSSNY will aggressively work with county and specialty medical societies across the State to collect examples of health insurers inappropriately denying payment for care, appropriately delaying patient access to needed treatment and abusive audit practices for redress by the New York State Department of Financial Services and the NYS Department of Health. MSSNY will educate physicians regarding strategies to assist in collecting examples for review by state oversight agencies, such as the use of relevant ICD-10 codes that identify in the electronic medical record when patients have difficulty accessing care due to inappropriate denials. (HOD 2021-56; Reaffirmed HOD 2022-61)

120.891           Enforcement of Administrative Simplification Requirements – CMS

The Medical Society of the State of New York takes the position that the AMA must advocate that:

there is parity in the enforcement of the HIPAA Privacy Rule and HIPAAA Administrative Simplification requirements; and that the CMS impose penalties on health plan violations of HIPAA with the same rigor it imposes penalties on healthcare providers for violations of MIPS and other requirements;

the CMS investigates all valid allegations of HIPAA Administrative Simplification Requirements thoroughly and offers transparency in its processes and decisions as required by the Administrative Procedure Act (APA); and

the CMS resolves all complaints related to non-compliant payment methods including opt-out virtual credit cards and illegal EFT fees.

MSSNY strongly disapproves of the failure by the CMS Office of Burden Reduction to effectively enforce the HIPAA Administrative Simplification Requirements as required by the law and its failure to impose financial penalties for non-compliance by health plans.  (HOD 2021-55) 

120.892           Patient Protection from Insurance Company Contract Disputes

The Medical Society of the State of New York will support legislation that permits employers the right during a policy year to seek an alternative health insurance plan for their employees when the initial contracted health insurance plan ends a participation agreement with a hospital system or physician group, and which materially impacts timely access to quality care by their subscribers. (HOD 2021-53)

120.893           Fifteen Month Lab Orders

MSSNY will advocate for legislation and/or regulation for all insurances to allow any standing laboratory order to be valid for up to 15 months before a new order is required. MSSNY will submit a resolution to the AMA seeking action by the Centers for Medicare/Medicaid Services (CMS) to allow standing laboratory orders to be active for 15 months. (HOD 2021-101) 

120.894           Prohibition of Insurer Processing Fee on Claims

MSSNY will advocate through legislation, regulation or other appropriate means, that health insurers be prohibited from charging physicians and other providers to process claims and make payments. This resolution will be sent to the AMA.  (HOD 2021-251)

120.895           Insurance Coverage for Scalp Cooling (Cold Cap) Therapy

MSSNY will seek by legislation and/or regulation, universal insurance coverage for Scalp Cooling (Cold Cap) Therapy. MSSNY will work with consumer groups to challenge insurers on Scalp Cooling (Cold Cap) Therapy medical necessity denials and encourage appeals to independent third-party reviewers.  The resolution will be sent to AMA as well. (HOD 2021-250)

120.896           Insurance Claims Data

The Medical Society of the State of New York (MSSNY) will seek legislation and regulation to promote open sharing of de–identified health insurance claims data. MSSNY will introduce a resolution to the AMA HOD to seek legislation and regulation to promote open sharing of de-identified health insurance claims data.  (HOD 2020-260) 

120.897           Reducing Prior Authorization Burden and Separate Payment When Not Part of a Patient Encounter

The Medical Society of the State of New York (MSSNY) will seek legislation or regulation that:

-restricts insurers from requiring prior authorization for generic medications,

-ensures the legislation or regulation contains disincentives for insurers demanding unnecessary prior authorizations, including payments to physicians’ practices for inappropriate prior authorizations,

-ensures the legislation or regulation requires that payment be made to the physician practice for services related to prior authorization when those services do not coincide with a visit,

-ensures that the legislation or regulation contains a requirement for an independent external review organization to review disputes involving prior authorizations and require insurer payments be made to the practice when the review organization agrees with the physician practice.

This resolution will be forwarded to the AMA for national support. (HOD 2020-252 and 2020-262) 

120.898           Prior Authorization Reform

The Medical Society of the State of New will advocate for practicing physician representation in peer-to-peer reviews and development of prior-authorization criteria and also to prohibit the use of prior authorization for medically necessary services and imaging performed during pre-approved surgeries or other invasive procedures. (HOD 2020-270) 

120.899           Private Payor Payment Integrity

MSSNY shall advocate for the NYS Department of Financial Services to require, at a minimum, private health insurers to pay for diagnosis and treatment options that are covered by government payers such as Medicare and that private insurers shall not be allowed to deny payment for treatment options as “experimental and/or investigational” when they are covered under government plans.  Such coverage shall extend to managed Medicaid, Workers’ Compensation plans, or NY No Fault Auto insurance companies. This resolution will be transmitted to AMA to cover managed Medicare and other federally regulated programs.  (HOD 2020-266) 

120.900           Paid in Full Insurance Check Payments

The Medical Society of the State of New York will seek legislation and/or regulation to ban the insurance companies from issuing “paid in full” on checks used to pay physicians and will investigate and provide guidance for best practices for responsible management of checks issued in this manner. (HOD 2020-263) 

120.901           Health Insurance that Fairly Compensates Physicians

MSSNY will advocate for insurance plans to compensate physicians enough to stay in practice independent of hospital employment. This resolution will be transmitted to the AMA for further advocacy for adequate compensation of physicians.  (HOD 2020-257)

120.902           COBRA for College Students

The Medical Society of the State of New York will call for legislation similar to COBRA to allow college students to continue their healthcare coverage, at their own expense, for up to 18 months after graduation or other termination of enrollment.  This resolution will be sent to AMA.  (HOD 2020-253) 

120.903           Bypassing Surprise Bill Good Faith Negotiation

The Medical Society of the State of New York will seek legislation and/or regulation that would prohibit insurance companies from the practice of making a small payment and filing a dispute without negotiation, which is not in the spirit of the Surprise Bill Law and MSSNY will monitor this practice by supporting its members in filing complaints to the NYS Department of Financial Services.  MSSNY will seek legislation and/or regulation which would require the insurance company to supply contact information for negotiation directly on the Explanation of Benefits (EOB). (HOD 2020-59)

120.904           Fertility Preservation Therapy Insurance Coverage for Patients

MSSNY will advocate for payment for fertility preservation therapy services by all payers when iatrogenic infertility may be caused directly or indirectly by necessary medical treatments as determined by a licensed physician, and will advocate for appropriate state regulation requiring payment for fertility preservation therapy services by all payers when iatrogenic infertility may be caused directly or indirectly by necessary medical treatments as determined by a licensed physician.  (HOD 2019-118)

120.905           Physician Credentialing Improvement

MSSNY will advocate for regulation or legislation asserting that, until an application is accepted or rejected, a physician who has submitted a completed application for credentialing may bill for services under the general supervision of a physician who is already credentialed by that plan. This shall be applied to all insurance plans, including state sponsored plans such as worker’s compensation.  (HOD 2019-115) 

120.906           Grandfathering of Medications that have been Prescribed for Over 1 Year

MSSNY will advocate that a physician be able to ensure continued insurer authorization for a particular medication that a patient has been using for over one year by noting on the e-prescription that the patient is stabilized on that medication.  (HOD 2019-68)

120.907           Nuisance Prior Authorizations

Prior authorizations for medication must have a sound clinical justification which would be available upon request from the Pharmacy Benefit Manager and which would include, but not be limited to, promotion of adherence to guidelines, promotion of generic alternatives, and prevention of adverse reactions.  MSSNY will advocate with the NYS Department of Health and NYS Department of Financial Services to prevent health insurers from imposing prior authorizations without appropriate clinical justification and to instruct Medicaid managed care contractors to approve prior authorizations for a minimum of one year. (HOD 2019-61)

120.908           Ensure Post Discharge Follow-Up Care with Original Treating Physicians

MSSNY will work with the New York State Legislature and other appropriate state agencies to ensure that patients treated by non-participating providers in the hospital promptly be authorized out of network coverage for follow up care to complete the current episode of care by the original provider.  (HOD 2019-261) 

120.909           Congenital Anomaly Insurance Coverage

The Medical State Society of the State of New York will seek legislation or regulation which requires insurance cover reconstructive services for congenital defects or anomalies which have resulted in a defect as determined by the attending physician.

MSSNY will also seek a requirement that insurance benefits for rehabilitative services when such treatment is incidental to or follows surgery resulting from injury, sickness or other diseases of the involved part, or when such treatment is provided to a covered dependent child because of congenital disease or anomaly which has resulted in a defect as determined by the attending physician.   (HOD 2019-251)

120.910           Board Certification Participation in Insurance Plans

The Medical Society of the State of New York supports legislation or regulation that prevents physicians from being denied participation in insurance plans based on board certification alone, when they have completed their residency and are candidates for board certification according to their respective specialty.  (HOD 2018-108) 

120.911           Diabetic Shoes

The Medical Society of the State of New York will work with the NYS Society of Orthopedic Surgeons, primary care societies, and the NYS Podiatric Association to create a standardized form to request diabetic footwear.  (HOD 2018-67) 

120.912           Reducing the Rate of Precertification Requirements

In an effort to improve patient care and reduce the unnecessary burden regarding precertification requirements for physicians, MSSNY will continue and expand its efforts to force health insurers to reduce the level of required pre-certifications and pre-authorizations physicians must obtain prior to rendering care.  (HOD 2018-264) 

120.913           Qualified Physicians on Preauthorization Phone Lines

The Medical Society of the State of New York will seek legislation or regulation requiring that prescribers be able to reach a qualified medical person promptly (within 10 minutes) on all telephone calls to third-party carriers for precertification, appeals, etc. and that the personnel qualified to adjudicate these requests would be limited to licensed physicians (allopathic or osteopathic), and that for special needs, telephone requests for pre-certifications and appeals could be adjudicated only be qualified personnel who were in the same specialty as the physician calling.  (HOD 2018-263)

120.914           Difficulty Obtaining Pre-Op Information for Insurers

The Medical Society of the State of New York will urge the Department of Financial Services to mandate that health insurers declare on their websites the specific pre-service criteria required for any medical service or surgical procedure that is subject to precertification.  MSSNY will work with insurers to ensure that a reasonable time frame be in place for notification should there be a medically necessary change to the actual surgery. (HOD 2018-262) 

120.915           Insurers’ Procedures Regarding Termination and Resignations

The Medical Society of the State of New York will urge the New York State Department of Financial Services (DFS) to require insurers to provide clear instructions for physicians who wish to terminate or resign from participation agreements;  specifically, the insurers should be required to publicize mailing addresses for termination/resignation requests, any wording that is required for these requests and the insurers should post these instructions in written publications and on websites (ie, a Termination/Resignation Request form might be included in the insurer’s Interactive Forms library).

Additionally MSSNY will urge the NYS DFS to require that when an insurer receives a physician’s termination/resignation request, it send the physician a written confirmation by email, fax, or certified mail, stating that it has received the request, the date on which the termination will take effect and listing instructions on how the physician is to handle claims that are being held or are currently pending in the insurer’s system.  (HOD 2018-255) 

120.916           Contract Non Renewals by Third Party Insurers:  Problems With the Insurers’ Notification Process

The Medical Society of the State of New York will urge both the Department of Financial Services (DFS) and the Department of Health (DOH) to require that insurers verify and maintain the accuracy of the physicians’ directory and that the DFS require insurers send notices of contract non-renewal via Certified Mail – Return Receipt Requested.

MSSNY will remind physicians about the New York State DOH Provider and Health Plan Look-Up Tool, which can be accessed at https://pndslookup.health.ny.gov, By entering the physician’s name and county, the website will display the plan(s) and physician practice location(s).  If needed, corrections to the practice location can be made and returned to the NYS DOH which will notify the plan(s) that correction is required.  (HOD 2018-254)

120.917           Printing Co-Pays & Deductibles on All Insurance Cards

The Medical Society of the State of New York will request that the New York State Department of Financial Services mandate all insurance companies print current copays, deductibles and date of issue on all subscriber health insurance cards. (HOD 2018-250)

120.918            MSSNY Statement on Increased Health Insurance Deductibles

MSSNY supports health insurance coverage that is affordable and usable for patients in terms of premium, deductible, coinsurance and/or copayment. (HOD 2017-59, referred to Council, substitute adopted June, 22, 2017)

120.919           MSSNY Support of Universal Health Insurance

The Medical Society of the State of New York will advocate for legislation to ensure that all New Yorkers have at least basic health insurance coverage. (HOD 2017-64)

120.920            Out of Network Insurance Benefit Availability in Individual Market and Self-Funded Plans

MSSNY will seek, through legislation and/or regulation, the availability of out-of-network benefits including plans utilizing usual, customary and reasonable (UCR) payment methodology for out-of-network benefits in all tiers, including the individual market and New York State of Health. The MSSNY Delegation to the American Medical Association (AMA) will introduce a similar resolution at the next meeting of the AMA House of Delegates for similar requirement in federally sponsored plans, federal exchange, and/or self-funded plans. (HOD 2017-61)

120.921              Sale of Health Insurance Across State Lines

The Medical Society of the State of New York opposes federal and state legislative proposals that permit the sale of health insurance products in a state that does not comply with that state’s law and regulations. This resolution will be introduced at the Annual AMA meeting calling for similar action. (HOD 12017-51)

120.922              Insurers Withhold Key Financial Information from Out-of-Network Physicians

MSSNY will seek legislation or regulation which would require important information contained in a Claim Remittance or Explanation of Medical Benefits be sent to all treating physicians. MSSNY will seek legislation or regulation which would prohibit insurers from using the term “co-insurance” when referring to the obligation of individual policy holders and suggest insurers to use a more applicable term such as “patient’s responsibility.” (HOD 2017-110)

120.923            Prompt Response to Physician’s Request for Patient Care Services Authorization

MSSNY will seek legislation and/or regulation requiring all insurance plans to respond in one business day to requests for services for the patient and if such response is not in the affirmative, then the response must include an option for the physician to access a fair appeal process. (HOD 2017-264)

120.924             New York State Insurance Fund Unfair Rule Changes

The Medical Society of the State of New York will work with all relevant agencies, including the Workers Compensation Board, to force the New York State Insurance Fund to return to the policy of providing physician offices with both the status of a claim and body parts under that claim prior to a consultation occurring. (HOD 2017-261)

120.925           Peer-to-Peer Reviews by Insurers

The Medical Society of the State of New York will seek legislation to change peer to peer review by insurers to include evidence-based criteria publicly available and to be conducted by a physician of the same specialty and responded to the physician practice on a timely basis via fax or electronically. This legislation should also limit peer to peer and prior authorization reviews to only those cases that do not fall within the evidence-based criteria. (HOD 2017-252; Reaffirmed HOD 2020-270; Reaffirmed HOD 2023-106; Reaffirmed HOD 2024-60)

120.926             Private Insurers and Managed Care Organizations Pre–Authorization/Pre–Certification Protocols

The Medical Society of the State of New York (MSSNY) will seek legislation or regulation applying to all insurers which will:

Require insurance companies to provide clear instructions in a timely manner about the procedure for obtaining a prior authorization;

Require that for each plan or product, the insurer post on its website a complete list of services requiring pre–certification/pre–authorization;

Require that after a physician has telephoned a customer service representative (CSR) to determine whether a service requires pre–certification/pre–authorization, the insurer will send a written confirmation of the CSR’s verbal statement by fax or e-mail to the physician;

Prohibit the insurer from denying a claim solely for lack of an electronic pre–authorization/pre–certification request, if (a) the CSR has stated verbally that the service does not require pre–authorization/pre–certification but that statement was inaccurate, and (b) the physician, relying on the CSR’s verbal statement, failed to submit an electronic pre–authorization/pre–certification request; and

Ensure that when pre-authorization is not required, a physician can request from the insurance company a written predetermination about whether a particular procedure will be covered for a particular patient, and that predetermination shall be binding. (HOD 2016-260 & 261)

120.927             Deleting State or Federally-Mandated Coverage

The Medical Society of the State of New York will seek federal regulation or legislation that prohibits self-insured health insurance companies from deleting coverage mandated by government. (HOD 2016-259)

120.928            Transfer of Insureds to Other Carriers without Proper Notification

The Medical Society of the State of New York (MSSNY) will work with the appropriate state agencies to enact regulation banning the transfer of insureds or contract term changes without appropriate and easy to understand written notice of at least 90 days prior to the planned transfer. (HOD 2016-258)

120.929            Improving Medical Insurance Customer Service

The Medical Society of the State of New York (MSSNY) will seek regulation or legislation which ensures that all coverage information be made available to health insurance customer service agents to review with patients during phone conversations.

MSSNY will seek regulation or legislation which ensures that all insureds be furnished with copies of their coverage directly through the insurer upon request and that a copy of an insured’s policy be made available through the online login at all times. (HOD 2016-255)

120.930            Centralized Insurance Registry

The Medical Society of the State of New York (MSSNY) working with the New York State Department of Health — Office of Health Insurance Programs will seek establishment of a centralized system of insurance eligibility accessible to all providers. (HOD 2016-254)

120.931            NYS Private Payer Medical Necessity Guidelines

MSSNY will support legislation and/or regulation which prohibit insurance companies from using proprietary guidelines to deny pre-authorization and/or payment. (HOD 2016-251)

120.932          Insurance Simplification of Explanation of Benefits (EOBs)

The Medical Society of the State of New York will seek regulation or legislation that would require all claims from a health care provider relating to a single encounter be reported together on the same EOB, rather than across multiple EOBs in order to make the claims process more simple and transparent. (HOD 2016-51)

120.933                Limitation on Outpatient Therapy Copayments

As a result of increased physical therapy co-pays, which often cause patients to delay medically necessary treatment, the Medical Society of the State of New York should seek legislation or regulation which would limit a patient’s out-of-pocket co-pay for a prescribed course of physical therapy treatment, thereby making it financially viable for a patient to obtain these needed services. (HOD 2015-266)

120.934               Payments by Medicare Supplemental Policies

The Medical Society of the State of New York will take appropriate action to educate MSSNY members through the E-news and the News of New York about their patients Medigap Plans so that physicians can, in turn, educate their patients’ about the benefits associated with the supplemental policies they have purchased. (HOD 2015-265)

120.935           Non-Experimental Status Determined by Centers for Medicare and Medicaid Services

The Medical Society of the State of New York will seek by regulation and/or legislation New York State policy/law requiring that any medical service deemed non experimental by the Centers for Medicare and Medicaid Services for government programs also be deemed non-experimental by private payors. (HOD 2015-254; Reaffirmed HOD 2019 in lieu of res 107)

120.936             Requiring Insurance Companies to Cover ADD/ADHD Medications

For children who have already previously been successfully stabilized on a specific ADD/ADHD medication, the Medical Society of the State of New York (MSSNY) will pursue legislation and/or regulation that requires an insurer to continue to cover, at lowest tier cost, or patient cost-share, that same medication for children, and do so without obstructions, such as prior authorization or required trials of alternate medications, if and when that insurer changes their formulary policies.

For children who have already previously been successfully stabilized on a specific ADD/ADHD medication, but change insurer, or have a change in policy program within that same insurer, MSSNY will pursue legislation and/or regulation that requires an insurer to continue to cover, at lowest tier cost, or patient cost-share, that same medication for children, and do so without obstructions, such as prior authorization or required trials of alternate medications, if and when that insurer changes their formulary policies. (HOD 2015-252)

120.937               HCV Testing and Treatment

The Medical Society of the State of New York will send a letter to the New York State Division of Financial Services seeking a requirement that commercial insurers provide coverage for the HCV test. MSSNY will seek, by legislation if needed, to ensure that commercial insurance coverage for the HCV test and access to HCV treatment is required. (HOD 2015-160)

120.938                 Out of Network Coverage Denials for Physician Prescriptions and Ordered Services

MSSNY will pursue regulation or legislation to prohibit any insurer from writing individual or group policies which deny or unreasonably delay coverage of medically necessary prescription drugs or services based on network distinctions of the licensed health care provider ordering the drug or service. (HOD 2015-69)

120.939                 Physician-Directed Medication Access

The Medical Society of the State of New York will continue to advocate for:

Legislation which will ensure that the physician’s judgment regarding the necessity of a particular medication for their patient prevails over an insurer’s judgment, including for all patients insured through Medicare and Medicaid;

Legislation or regulation that would prohibit an insurer from denying care for needed treatment or medications unless it is reviewed by a physician of the same specialty as the treating physician; and

Legislation, regulation, or other appropriate means to assure that health plans consult with appropriate specialty physicians in the creation of formularies and policy regarding drug-tiers. (HOD 2015-53; Reaffirmed HOD 2016-67)

120.940               Patient Educational Tools on Insurer Administrative Policies

The Medical Society of the State of New York will develop a series of educational tools for members to give to their patients that will inform patients about policy and administrative problems caused by insurance plans making it more difficult for physicians to provide needed, quality health care and these Patient Educational Tools on insurer processes will state how insurers have interfered with physicians or otherwise constrain physicians from delivering what they believe to be the best quality care. (Amended and adopted by Council, 11/20/2014. From HOD 2014-257; Reaffirmed HOD 2024)

120.941               Affordable Care

The Medical Society of the State of New York will advocate for regulation and legislation which provides that insurers give reasonable credit for out of network expenses based on Fair Health toward a participant’s annual deductibles and out of pocket maximums. MSSNY will submit a resolution to the annual meeting of the American Medical Association seeking federal regulation and legislation to provide that insurers give reasonable credit for out of network expenses toward a participant’s annual deductibles and out of pocket maximums. (HOD 2014-253; Reaffirmed HOD 2024)

120.942             Thoroughly Informing Patients and Physicians About Out-Of-Network Benefit Reduction and Cancellation

The Medical Society of the State of New York (MSSNY) will take all possible appropriate steps, utilizing all possible methods including public relations, to fully and thoroughly educate patients and the public about the emerging realities of out-of-network benefits, and the Medical Society of the State of New York will make every conceivable effort to communicate more fully and completely with its membership regarding what will transpire regarding out-of-network care since physicians too are under-informed. (HOD 2014-254; Reaffirmed HOD 2024)

120.943               Physicians and Health Care Institutions as Providers of Health Insurance

In the case where a provider or health care institution provides such insurance it should be held to the highest standards and oversight to prevent conflicts of interest that impair quality care; and any institution in the business of health care insurance have on its governance board and/or advisory boards, community providers as long as they are not employees of the institution providing such insurance. (HOD 2014-112; Reaffirmed HOD 2024)

120.944           Changes in Pre-certification for Medications to Reduce Delays

The Medical Society of the State of New York will continue to advocate to reduce the circumstances when pre-authorization for needed patient medications are required, including eliminating the requirement for annual re-authorization once a prior authorization for a prescription medication has been approved.  The Medical Society of the State of New York will advocate to ensure that health plan pre-authorizations for prescriptions be completed within 24 hours. (HOD 2014-58; Reaffirmed HOD 2015-53; Reaffirmed HOD 2019 in lieu of res 68; Reaffirmed HOD 2023-106)

120.945                  Access to Timely Care

The Medical Society of the State of New York will advocate for legislation or regulation to assure the right of a patient to have insurance coverage which permits them to be treated by an out of network physician of the patient’s choice if the plan network is inadequate to enable a patient to be treated by a needed specialist within 14 days of the patient’s request, with payment based upon usual and customary rates. (HOD 2014-60; Reaffirmed HOD 2024)

120.946               Cost-saving Public Coverage for Renal Transplant Patients

MSSNY will ask the AMA to support private and public mechanisms that would extend insurance coverage for the full spectrum of renal transplant care for the life of the transplanted organ; and ask the AMA to offer technical assistance to individual state and specialty societies when those societies lobby state or federal legislative or executive bodies to implement evidence-based cost-saving policies within public health insurance programs. (HOD 2013-266; Reaffirmed HOD 2023)

120.947              Collapse Individual and Small Group Insurance Markets

MSSNY will seek legislation and/or regulation to eliminate the (newly obsolete) health insurance premium pricing differential that exists between the individual and small group pools. (HOD 2013-264; Reaffirmed HOD 2023)

120.948             Third Party Payer Coverage of Follow Up Exams for Patients with Dense Breast Tissue

MSSNY will seek legislation to require insurance companies and other third party payers to pay for follow up exams for women who receive a report of dense breast tissue.

(HOD 2013-154; reaffirmed HOD 2023)

120.949             Health Insurance Policies for Small Groups

In view of health insurance companies moving to eliminate many or all of the health insurance plans being offered to small groups (2-50 employees), while also dramatically reducing the financial incentives for brokers to market their plans, and continuing to raise premiums on small businesses at rates that are making such insurance unaffordable, that the Medical Society of the State of New York urge the Department of Financial Services to require all health insurance companies operating in the State of New York to offer a wide array of health insurance to small groups, both within the health insurance exchange and outside of the exchange. (HOD 2012-55; referred, modified & adopted by Council 11/29/2012; Amended and Reaffirmed HOD 2022)

120.950           Regulation and Transparency of Imaging Benefit Managers’ Contracts

The Medical Society of State of New York will seek legislation that any health plan, or its business partner, conducting prior authorization for non-urgent and non-emergent services or procedures 1) respond to these requests within two business days; 2) utilize recognized standards of care and comply with any published specialty society-approved practice guidelines; 3) ensure that their authorization criteria conform with their health plan’s published policy available to the public for any and all service needing prior authorization; and 4) in the event of denied authorization, an expedited peer-to-peer appeal be conducted within the day (24-hour period) so that no potentially harmful delays befall the patient and that compliance with these rules be monitored by the NYS Department of Health. (HOD 2012-253; Reaffirmed HOD 2020-270)

120.951             Clear Statement of Coverage on Health Insurance ID Cards

The Medical Society of the State of New York (MSSNY) will work with insurers to develop standardized information to be required on all health insurance ID cards which clearly states services, co-pays, and other vital coverage data purchased by the insured. (HOD 2012-255; Reaffirmed HOD 2016-256)

120.952            Insurance Companies Dis-enrollment of Participating Physicians: SUNSET HOD 2022

120.953           Transparency in Insurance Contracts:

MSSNY will seek legislation and/or regulation that would enforce health insurance plans to clearly and transparently declare what exactly is covered and not covered in each of their plans in a plain, simple and concise summary, with carefully documented exclusions to coverage, in a standardized format to be approved by the New York State Superintendent of Insurance.  Also such legislation and/or regulation should state that once these limitations of coverage are outlined they cannot be changed without first notifying the insured of these changes in a timely manner, sufficient enough to allow an insured the ability to change policies without disruption to healthcare coverage.  (HOD 2010-260; Reaffirmed HOD 2020)

120.954           Child Health Plus Program Funding:

MSSNY will continue to work with New York’s Congressional Delegation and the AMA to assure that federal funding for care provided to beneficiaries of the Child Health Plus and Medicaid programs in New York is not diminished in the future.  (HOD 2010-91; Reaffirmed HOD 2020)

120.955           Truth in Out-of-Network Healthcare Benefits Act:

MSSNY will continue to seek enforcement of the law requiring insurance companies to provide to potential purchasers the true expected out-of-pocket costs if patients to out of network.  (HOD 2010-58; Amended and reaffirmed HOD 2020)

120.956           Out-of-Network Care by Health Plan Providers:

MSSNY will petition health plans as well as the New York State Insurance Department to allow the health plan’s physician to charge a subscriber as an out-of-network provider when the subscriber is not an enrolled member of the physician’s specifically contracted health plan product. (HOD 2009-262; Reaffirmed HOD 2019)

120.957           Outsourcing of Claims:

MSSNY will take all appropriate steps including, if necessary, the passage of legislation to assure that health insurance companies which subcontract with third party vendor(s) located in a foreign country for claims processing, utilization review or for any other service adhere to all appropriate federal and state legal requirements for the prompt adjudication of claims for payment, utilization review and patient information privacy.  (HOD 2009-105; Reaffirmed HOD 2019)

120.958           Eligibility for Enrollment in Family Health Plus: SUNSET HOD 2019

120.959            Revision of the Federal Tort Claims Act:

MSSNY will endorse the proposal that all patients whose care is funded in all or in part by federal funds, and/or whose care is delivered in facilities funded in all or in part by federal funds, such as those patients covered by Medicare, Medicaid, Railroad retirement benefits, SCHIP, insurance purchased with pre-tax dollars, treated in not-for-profit facilities, etc., be brought under the jurisdiction of the Federal Tort Claims Act. Also, the MSSNY delegation to the American Medical Association is requested to take this issue to the 2009 AMA House of Delegates for action on the federal level. (HOD 2009-75; Reaffirmed HOD in lieu of 2017-107)

120.960           Assuring Seamless Coverage for Patients Changed from HMOroducts into PPO Products:  SUNSET HOD 2019

120.961          Impediments to Obtaining Pre-authorizations for Medically Indicated Diagnostic Tests:

MSSNY will take appropriate steps including, if necessary, seeking the enactment of legislation and regulation, to eliminate unnecessary impediments imposed by health insurance companies to obtaining pre-authorization, including reducing the need and time for obtaining pre-authorization. (Council 3/3/08; Reaffirmed HOD 2014-58; Reaffirmed HOD 2024)

120.962                 United States Health Care and Gratuitous Privatization:

MSSNY supports those health care policies that favor insurance products to achieve the health care goals of quality, cost containment and interoperability, only when the evidence in support of the superiority of such insurance products is composed of unbiased, scientifically rigorous and medically sound studies.  (HOD 2008-93; Reaffirmed HOD 2018)

120.963                 Retail Clinics:

MSSNY will pursue legislation, regulation, or other appropriate means to (a) assure that a retail clinic that receives insurer reimbursement be required to comply with existing standards for the operation of medical practices; and (b) prohibit health plans from incentivizing the utilization of health care in retail stores through techniques including but not limited to the charging of less expensive co-pays. (HOD 2008-68; Reaffirmed HOD 2018)

120.964               Universal Bill:

MSSNY will seek legislation or other appropriate means to assure that all durable medical equipment (DME) vendors have a universal bill that is consumer-friendly and clearly states what was paid by the health plan, secondary insurer and what is owed by the patient and that these bills are received in a timely fashion. (HOD 2008-61; Reaffirmed HOD 2018)

120.965             Medically Necessary Procedures and Pre-certification and Pre-authorization Protocols:

MSSNY will:

1. Seek the enactment of legislation, regulation or other appropriate means to eliminate the need to obtain pre-authorization for certain procedures and tests that are clearly indicated, including for urgent and emergency care, based upon a patient’s particular health condition as defined by relevant physician specialty society guidelines;

2. Take appropriate steps to assure that health plans obtain meaningful clinical input from New York physicians representative of all specialties, through practicing physician liaison committees, in determining which services should require pre-authorization or pre-certification;

3. Take appropriate steps to assure that health plans promptly respond to required pre-authorization requests for tests within 24 hours, including the imposition of meaningful penalties on health plans, and requiring payment for the requested services when such authorization is not received in a timely manner;

4. Advocate for a statutory definition of “medical necessity” which gives appropriate discretion to a physician requesting the health care service or treatment for the patient, provided the care is consistent with generally accepted standards of medical practice, and clinically appropriate to the patient’s condition. (HOD 2008-50; Reaffirmed HOD 2016-262)

120.966           Coverage by Carriers for Annual Physical Examination in Healthy NY Program:

MSSNY will encourage the Healthy NY Program to negotiate a benefit package that allows for an annual health maintenance visit.  (HOD 2008-264; Reaffirmed HOD 2018)

120.967           Hearing Aids:

MSSNY will work with the American Medical Association to encourage all insurers, including Medicare, to provide coverage for hearing aids for individuals determined by professionals to be hearing impaired.  (HOD 2008-263; Reaffirmed HOD 2018)

120.968           Waiver of Primary Care Referral Requirements for Skilled Nursing Facilities and Sub-Acute Rehabilitation Facilities:

MSSNY will pursue legislation and/or regulation to simplify and make transparent the health coverage of Skilled Nursing Facilities/Sub-Acute Rehabilitation Facility residents, by waiving the primary care referral requirement so that patients receive timely and appropriate treatment and appropriate reimbursement is provided for these services.  (HOD 2008-262; Reaffirmed HOD 2018)

120.969           Removing Barriers to Care for Transgender or Gender Variant Patients:

MSSNY supports public and private health insurance coverage for treatment of gender dysphoria, and opposes categorical exclusions of coverage for treatment of gender dysphoria when prescribed by a physician.  (HOD 2008-171; amended and reaffirmed HOD 2018)

120.970           Health Coverage Coalition for the Uninsured:

MSSNY approves the conclusions of the Health Coverage Coalition for the Uninsured and express its concern that additional issues of significance should be also addressed by HCCU including but not limited to the burdensome cost associated with the administration of current health care coverage, the need for redress of the medical liability problem, and the need to obtain leverage in the health care market through collective negotiation. (Council 3/5/07; Reaffirmed by Council 11/29/2012 in lieu of 2012-260; Reaffirmed HOD 2022)

120.971           Medical Outsourcing:

MSSNY will request legislation to prevent insurance companies from incentivizing subscribers in this state to have to go overseas for medical treatment that could be provided locally and, through the American Medical Association, request federal legislation to prevent insurance companies from incentivizing subscribers to go overseas for medical treatment that could be provided locally. (HOD 2007-263; Reaffirmed HOD 2017)

120.972           Association Health Insurance:

MSSNY will seek legislation or regulation to enable insurers to provide association-specific health insurance alternatives for 501(c)(6) not-for-profit associations in the State of New York. (HOD 2007-211; Reaffirmed HOD 2017)

120.973          Health Promotion Visits:  (Sunset HOD 2017)

120.974         Access to Health Insurance for Domestic Partners: (Sunset HOD 2016)

120.975         Home Visits:

MSSNY work to assure appropriate reimbursement for rendering care to homebound individuals. (HOD 2004-64; Reaffirmed HOD 2014; Reaffirmed HOD 2024)

120.976          Geriatric Care:

MSSNY will work to assure appropriate reimbursement by all payors for care provided to the elderly. (HOD 2004-62; Reaffirmed HOD 2014; Reaffirmed HOD 2024)

120.977           Patients’ Out of Pocket Financial Responsibility for Emergency Room Services Provided: SUNSET HOD 2014

120.978           Public Access to Health Insurance Policy Options Available to Government Employees:
SUNSET HOD 2013

120.979            Patient Responsibility for Notification of Change in Insurance Coverage:  SUNSET HOD 2013

120.980            Clean Claim: Sunset HOD 2011

120.981             Standardized Referral Form: SUNSET HOD 2014

120.982            “Bare Bones” Health Insurance Policies: SUNSET HOD 2014

120.983             Payment for Clinical Preventive Services: (Sunset HOD 2017)

120.984            Parity in Reimbursement for Mental Health Services SUNSET HOD 2014

120.985            Call for the Closure of Wellcare of New York SUNSET HOD 201

120.986           Non-Assignability Clauses in Health Insurance Contracts:

MSSNY supports the patients’ right to assign their health insurance benefits to their physician, and shall seek legislation that would prohibit non-assignability of benefits clauses from all health insurance contracts.  (HOD 1999-61; Reaffirmed HOD 01-66; HOD 2008-56; Reaffirmed HOD 2009-63; Reaffirmed HOD 2019)

120.987          Multiple Product Lines:

MSSNY through the American Medical Association will seek Federal Legislative action to challenge health insurers who mandate the commitment of physicians to all (or multiple) product lines under a single contractual agreement as a condition for their participation with such organizations.(Council 12/18/97; Reaffirmed HOD 2014; Reaffirmed HOD 2024)

120.988            MSSNY Position on Child Health Plus Program (CHPlus): SUNSET HOD 2014

120.989           Routine and Refractive Eye Examination:

It is MSSNY’s position that third-party payors make it abundantly clear to patients that eyeglass riders, routine eye examinations, vision care services, vision benefits, vision aid benefits, vision care benefits, eyeglass benefits and any such benefits, as desirable as they may be, do not substitute for a full medical eye examination on a regular basis by a qualified ophthalmologist, and that when eyeglass benefits are provided, that such benefits provide coverage for a refractive examination and prescription of eyeglasses by an ophthalmologist or optometrist of the patient’s choice. MSSNY will coordinate efforts with medical specialty societies to introduce legislation requiring third-party payors to use uniform and precise language to describe benefits provided in eyeglass benefits and riders, and make it clear to patients that such examinations do not substitute for a full medical eye examination on a regular basis. (HOD 1998-78; Reaffirmed HOD 2014; Reaffirmed HOD 2024)

120.990            Physician Notification of Insurance Payments Made Directly to Patients:

MSSNY will seek legal or regulatory action to require that insurance carriers be mandated to notify physicians of the amount and date of insurance claim payments made directly to their subscribers, regardless of the physician’s participation status in the plan. (HOD 1998-52; Reaffirmed HOD 2014; Reaffirmed HOD 2024)

120.991           Certain Types Of Well Examinations To Be Covered By All Insurers: SUNSET HOD 2014

120.992          Insurance Companies To Cover Screening Mammography:

MSSNY will seek requiring all health insurance products to cover mammography whenever the patient’s physician deems it medically appropriate. (HOD 1997-255; Modified and reaffirmed HOD 2014)

120.993        Smoking Cessation Reimbursement: SUNSET HOD 2014

120.994        Insurers To Cover Hepatitis B Immunization: SUNSET HOD 2014 (Reaffirmed HOD 2024)

120.995         Parity of Coverage for Mental Illness, Alcoholism and Substance Abuse in Medical Benefits Programs endorsed by MSSNY: SUNSET HOD 2014

120.996        Standardized Insurance Claim Forms: SUNSET HOD 2014

120.997         Truth in Health Insurance:

MSSNY takes the position that all health insurance literature and contracts should be mandated to use a standardized form, written in laymen’s terms (easy to understand language), wherein excluded diseases, diagnoses, and medical procedures are appropriately identified in policies of contract holders. As a means of allowing subscribers to make informed decisions concerning their health insurance choices, the Medical Society of the State of New York is urging the New York State Insurance Department to support legislation which would amend the insurance law in relation to the adoption of current procedural terminology for use by health insurers, as well as requiring insurers to release information on the mode of payment in addition to the actual reimbursement for services rendered to enrolled subscribers. (HOD 1992-37; Reaffirm HOD 2014; Reaffirmed HOD 2024)

120.998        Reimbursement When Patients Refuse to Sign Health Insurance Forms:

MSSNY is urgently requesting the New York State Department of Insurance to draft measures which would ensure that health insurance companies be obliged to reimburse physicians for documented medical services performed in accordance with the patient’s insurance plan whether or not the patient agrees to sign the insurance forms. (Council 7/23/92; Reaffirmed HOD 2014; Reaffirmed HOD 2024)

120.999          Health Insurer Abuses:

MSSNY has urged the Superintendent of Insurance to enhance the means by which consumer and physician complaints regarding health insurance programs are addressed in a timely, informed and effective manner, through: (1) Development and identification of clearly defined complaint and review procedures; (2) Imposition of penalties designed to deal with insurance carrier abuses; (3) Provisions of 1-800 number enabling consumer and physician access to appropriate personnel associated with established appeals and grievance processes.

MSSNY is vigorously pursuing legislation or regulation to limit health insurance abuses which would include specific requirements with respect to the responsibility of the Superintendent of Insurance to more adequately monitor the activities of health insurers in the State. (HOD 1991-34; Reaffirmed HOD 2014; Reaffirmed HOD 2016-262)