Weekly Checkup

Network Adequacy Starts With Having Enough Clinicians

This week, the Trump Administration quietly exempted foreign physicians from its visa-processing freeze, allowing U.S. Citizenship and Immigration Services to resume processing work permits and visa extensions for foreign-born physicians from countries under the administration’s travel ban. This decision is a welcome development, and not merely because it ameliorates disruption for hospitals and physician practices. The visa exemption reflects a simple economic truth: Immigration expands productive capacity, and in health care that capacity is immediately visible. A doctor who can enter the United States, complete training, renew work authorization, or join a practice expands the system’s ability to see patients. That is a pro-growth access policy.

This exemption is also a useful entry point into a larger health policy debate. Network adequacy is usually treated as an insurance compliance issue, and the debate often focuses on whether a plan has enough providers, whether directories are accurate, and whether beneficiaries can reach primary care physicians, specialists, hospitals, and behavioral health clinicians within reasonable time and distance standards. These questions are important. A plan network should be real, current, and usable. Regulators should contemn ghost networks, stale directories, and benefit designs that promise access without delivering it.

All health plans have varying degrees of network adequacy requirements. For Medicare, this matters enormously given the health burden facing beneficiaries. An aging population means greater demand for cardiology, oncology, neurology, primary care, behavioral health, home-based care, and post-acute services. A plan network that looks adequate on paper may still fall short if the underlying workforce is not growing fast enough to meet beneficiary needs.

Still, the sharper question is whether the underlying health care labor market is large enough to support the networks policymakers expect. A plan can contract only with a clinician that is actually available in each market. A provider directory may suffice as a consumer tool, but it cannot train a new neurologist, recruit a rural psychiatrist, or keep a primary care practice from closing. Network adequacy rules police the insurance architecture of access. Workforce policy determines whether there are enough clinicians to populate it.

That is why the physician visa exemption should be treated as a model for broader thinking. The goal should be to increase the supply of health care providers in the United States. A clear pathway to doing so is making it easier for qualified clinicians to enter, train, practice, and stay. But other policy considerations can also address current and projected workforce shortages. The American Medical Association reports that almost 325,000 international medical graduate physicians practice in the United States, accounting for roughly one-quarter of the physician workforce. Many serve in areas and specialties where recruitment is difficult, including rural communities, safety-net settings, and primary care. For beneficiaries in those markets, foreign-trained physicians are not a marginal supplement to the system. They are often part of the basic access infrastructure. Immigration policy, therefore, is health care access policy.

At the same time, immigration is only one piece of the solution. The United States also needs to train more clinicians domestically. The Association of American Medical Colleges projects a shortage of up to 86,000 physicians by 2036. The Health Resources and Services Administration’s workforce projections show an even worse picture, with projections that nonmetro areas will face a 58 percent shortage of primary care physicians by 2038.

Graduate medical education (GME) is an important part of the response. Congress has recently added Medicare-supported residency slots, including 1,000 new positions authorized under the Consolidated Appropriations Act of 2021 and 200 more beginning in fiscal year 2026. Those additions are constructive, but they are incremental. A serious health care access agenda should connect future GME growth more deliberately to shortage specialties, primary care, behavioral health, and underserved geographies, and not just in the Medicare program.

Scope-of-practice reform is also a key lever. Increasing the supply of qualified providers allows patients faster access to health care, often prevention-focused primary care. This does not require all clinicians to be interchangeable. Physicians, nurse practitioners, physician associates, pharmacists, and other professionals have different training, roles, and clinical strengths. But a robust access strategy should allow every clinician to practice at the top of their training, particularly in primary care, chronic disease management, medication management, preventive services, and behavioral health integration. For beneficiaries in underserved markets, these distinctions can affect whether care is available at all.

The physician visa exemption is therefore worth welcoming on its own terms. Immigrants are integral to the U.S. health care workforce, and policies that allow qualified clinicians to train, work, and remain in the United States can directly improve patient access. It reflects the basic reality that immigration can strengthen the economy, support health care delivery, and expand patient access. While less flamboyant than a new federal benefit or a major payment overhaul, immigration policy can shape whether patients can actually get care. If policymakers want to solve larger health care access issues, they should pursue a broad workforce agenda that includes immigration, GME, scope-of-practice modernization, and smarter deployment of every qualified clinician.

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