NY's Behavioral Health Access Standards Are Live: Is Your Provider Data Ready?

The July 1 deadline has passed. Compliance isn’t optional, and provider data is the backbone.

‍Enforcement Starts Now: The Behavioral Health Network Adequacy Rule in NY Is Active

As of July 1, 2025, New York’s new behavioral health access and network adequacy standards are in effect. Adopted jointly by the Department of Financial Services (DFS) and the Department of Health (DOH), these regulations apply to:

• Commercial health plans (Article 42, 43, and 44 insurers)

• Medicaid Managed Care Organizations (MCOs)

While the core requirements are aligned, each regulator has issued its own FAQ guidance outlining expectations, documentation requirements, and enforcement mechanisms.

What Do the Network Adequacy Regulations for Behavioral Health Services Require?

At its core, the new regulation amends 10 NYCRR Part 98 to ensure access to behavioral health services in New York through five pillars of compliance:

• Time and distance standards

• Appointment availability tracking

• Up-to-date provider directories

• Complaint resolution systems

• Compliance reporting and audit readiness

These requirements are enforceable, and plans must be able to prove compliance using accurate, accessible provider data.

How Are Commercial Health Plans and MCOs Impacted By the New Regulations?

Here’s what compliance, legal, and provider ops teams need to know, depending on the type of plan you manage.

For Commercial Health Plans (DFS-Regulated)

Source: DFS FAQ on Behavioral Health Access Standards

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DFS emphasizes digital-first directories and real-time provider availability — not just self-attested access.

For Medicaid Managed Care Plans (DOH-Regulated)

Source: DOH FAQ on 10 NYCRR Part 98.5

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DOH encourages coordination with OMH and OASAS and expects validated access methodologies.

Why This Regulation Is So Challenging

Behavioral health networks are dynamic and high-churn, creating ghost networks. Many plans still rely on:

• Manual roster ingestion

• Siloed or vendor-owned systems

• Outdated directories

• Inconsistent appointment availability tracking

These conditions make it nearly impossible to prove compliance, especially under active enforcement.

How Leap Orbit Helps Health Plans and MCOs Comply

Leap Orbit’s Convergent platform delivers real-time provider data infrastructure purpose-built for regulatory compliance, including the new behavioral health standards.

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Whether you need to stand up one point solution or modernize your entire system, Leap Orbit helps you scale compliance without rebuilding from scratch.

Enforcement Has Begun. What’s at Stake?

• Financial penalties or sanctions

• Public noncompliance reporting

• Plan contract risk (especially for MCOs)

• Member churn due to behavioral health access failures

Provider data is often the silent barrier to compliance, or the fastest path to audit readiness.

Let’s Fix Your Provider Data at the Source

Leap Orbit helps New York health plans and MCOs build the provider data infrastructure needed to confidently meet behavioral health access standards. We offer:

• Fast-start compliance packages

• Modular, interoperable solutions

• Support for both DFS and DOH documentation

Contact us today for a compliance readiness check or demo.