For issuers entering or expanding on the Exchange
Clear QHP certification without a network scramble.
Marketplace certification runs on an annual clock with little forgiveness. The Essential Community Provider threshold and county-level time-and-distance standards are where issuers most often get sent back.
No pitch. If it fits, the next step is a two-week diagnostic: fixed fee, no commitment past it.

Where it usually breaks
Sound familiar?
- The ECP threshold is short and the contracts aren't signed yet
- County-designation rules change what adequate even means
- Certification timelines collide with contracting reality
- Network breadth is fighting your premium target
What we take off your plate
One team for the whole build.
- ECP strategy & contracting
- Identify, recruit, and paper the essential community providers that count.
- County-level adequacy
- Time-and-distance modeled by county designation, gaps ranked by impact.
- Certification filing support
- Network templates and narratives assembled to survive review.
- Justifications & exceptions
- Defensible write-ups where the market genuinely cannot supply.
The plan
Three steps, with dates.
- 1
Diagnose
Where you stand against this year's QHP standards.
- 2
Build
Close ECP and specialty gaps against the filing date.
- 3
Hand back
A certified network and the cadence to renew it.
What success looks like
- ECP threshold met with signed agreements
- Certification cleared without a resubmission cycle
- A renewal process that isn't a fire drill next year
Not sure where your build stands?
Eight questions, two minutes. See your weak spots and what we'd fix first. No email required.
From our playbook
The QHP standards, explained.
- Regulatory · 12 min readACA Marketplace network adequacy: the QHP standards, explainedEntering the ACA Marketplace? Learn the QHP network adequacy standards — time-and-distance, wait times, ECP thresholds — and how they differ from Medicare Advantage.Read it
- Regulatory · 8 min readEssential Community Providers: the Marketplace requirement plans underestimateThe ECP standard trips up Marketplace filings every year. What Essential Community Providers are, the 35% CMS threshold, write-ins, and how to build early.Read it
- Regulatory · 11 min readHow telehealth counts toward network adequacyCMS gives Medicare Advantage plans a 10-point telehealth credit for certain specialties. See how it works, which specialties qualify, and how to use it honestly.Read it
- Regulatory · 7 min readThe No Surprises Act changed your adequacy obligationThe No Surprises Act was framed as a billing reform. Its implications for network adequacy and contracting leverage are larger than most plans planned for.Read it
- Regulatory · 12 min readGhost networks: why provider directories lie — and how to fix yoursGhost networks break access and trigger enforcement. Learn why provider directories go stale, what CMS and the No Surprises Act require, and how to fix yours.Read it
- Contracting · 9 min readBenchmarking fee schedules to Medicare — and negotiating from thereWhy provider fee schedules are set as a percent of Medicare, how to build a defensible benchmark by specialty and geography, and how to negotiate from there.Read it
Talk to the founder
I've watched a lot of builds go quiet around week six. Usually it isn't strategy. It's that nobody owns the hard middle. Tell me where yours is stuck and I'll tell you straight whether we can help, and what I'd do first.
Dave Smith
Founder, Kearny Street Management
Building provider networks since 2002, for payers and for providers.
A 20-minute call. No pitch and no slides, just a straight read on where your build stands.