Mandatory Closed Networks

Understanding the Mandatory Closed Networks Requirement

Under Session Law 2026-41, the North Carolina General Assembly amended Article 3 of Chapter 108D to:

Require all prepaid health plans (PHPs) to close their Network, and permit PHPs to exclude providers from their Networks, for Peer Support Services and Research-Based Behavioral Health Treatment (RB-BHT) Services; and
Require the Children and Families Specialty Plan (CFSP) to operate a closed Network for Intensive In-home Services, Multisystemic Therapy, Residential Treatment Services, services provided in Psychiatric Residential Treatment Facilities, and Community Support Team services.

This webpage is designed to summarize these changes and address common questions that have been raised to the Department regarding implementation of Session Law 2026-41.

Developing and Maintaining a Closed Network

While this change in statute does allow PHPs to close provider networks for peer supports and RB-BHT, it does not describe, place limitations on, or otherwise specify how PHPs shall develop or maintain their closed networks. The Department expects each PHP to develop and maintain a provider network in a manner that is consistent with all applicable federal and state laws, and the terms of the PHP’s contract with the Department. The Department will monitor PHP compliance with the Department’s availability, access and quality goals.

In accordance with the terms of the PHP contracts with the Department, PHPs are required to adequately and timely cover services out-of-network for a member if the PHP is unable to provide the covered service within its current network.

Can a Health Plan Limit New Locations for Providers Already In Network?

Yes. PHPs must maintain a closed Network for the specified services and may exclude providers from their closed network, and does not further dictate or specify how PHPs must implement their closed networks.

Accordingly, PHPs have discretion in how they develop and maintain their closed networks, to the extent consistent with applicable State and federal law, the terms of the PHP’s contract with the Department, the terms of existing provider contracts, and the PHP’s closed network processes and procedures. Providers interested in opening new locations should reach out to their contracted health plans.

Can a Health Plan Limit New Providers at an Existing Location for In-Network Status?

Yes. The same principles described above apply. Session Law 2026-41 grants PHPs discretion to develop and maintain closed networks, including decisions about adding new providers at an existing location, provided the PHP’s actions comply with state and federal laws, the PHP’s contract with the Department and its internal networkmanagement policies. Providers interested in opening enrolling addition providers at existing locations should reach out to their contracted health plans.

When can a Health Plan Implement its Closed Network for Peer Support and RB-BHT services?

These requirements are effective as of July 7, 2026.

What happens if a Member is Experiencing Issues Accessing Care for Services that are part of a Closed Network?

Members may contact their health plan directly, review the health plan’s online provider directory to identify in-network providers, or contact the NC Medicaid Ombudsman for additional support.

Contacts

Health Plan Contacts and Resources

Providers may visit the Health Plan Contacts and Resources webpage for health plan directories, provider manuals and contact information.

NC Medicaid Ombudsman

For additional support, providers and members may contact the NC Medicaid Ombudsman:

Phone: 877-201-3750 (members)
Phone: 866‑304‑7062 (providers)
Email: Medicaid.ProviderOmbudsman@dhhs.nc.gov