Health Net: Standardized Language Updates for Large Group Plans

On March 15, 2025, the Department of Managed Health Care (DMHC) issued All Plan Letter (APL) 25-004, implementing provisions from Assembly Bill (AB) 118. This regulation requires all health plans to adopt standardized Evidence of Coverage (EOC) and Disclosure Form (DF) language. The first part of the standardized EOC/DF process includes the following sections:

• Exclusions and Limitations
• Member Rights and Responsibilities
• Definitions

This requirement applies to Large Group contracts issued, amended, or renewed on or after January 1, 2026. All EOCs and DFs for Large Group plans renewing on or after that date will be updated to reflect the standardized language for the sections noted above.

Example of a Changes Under APL 25-004:

To help illustrate the types of updates being made, here are a few high-level examples based on the DMHC’s standardization requirements:

• "Covered Benefits": Custom language may be replaced with DMHC’s standardized definition, which typically states:
  "Health care services that are medically necessary, not specifically excluded, and listed in the Evidence of Coverage."
• "Evidence of Coverage (EOC)": Plans will adopt a consistent definition, such as:
  "A document issued by the health plan that describes the benefits, exclusions, limitations, and conditions of coverage for members enrolled in the plan."
• "Exclusions and Limitations": Language will be revised to align with DMHC’s format. For example:
  "Acupuncture Services: This ["Plan" or Product Name] does not cover acupuncture services, except [as described in this EOC in [SECTION XX] or] as required by law."

For a complete list of definitions and required updates to the "Exclusions and Limitations" and “Member Rights and Responsibilities” sections, please refer to DMHC APL 25-004.

These updates are intended to align language across plans and are not expected to impact plan benefits or member coverage.

Please note: Broker contracts are not impacted by this change.

Internal and external documents will be assessed for alignment with DMHC’s standardized definitions, where applicable.