Do preventive services have to be covered at all for out-of-network providers?
This is a difficult question, and carriers are cautioned to proceed carefully if they choose to exclude out-of-network preventive services from a plan that otherwise does contain benefits for non-network providers. However, because there is no state law that requires carriers to provide out-of-network preventive services, we believe at this time it is not necessary to provide an out-of-network benefit for preventive services, even though other health care services may be covered. We would caution that HHS may come out with a rule that does require out-of-network coverage for preventive services, and may even preclude any cost sharing for these services.