Oscar Health Transitions Provider Contracts to Oscar Management Corporation: What Every In-Network Provider Must Know

Analysis of Oscar Health’s Notice of Entity Expansion and Exhibit 7.3 — February 2026

By Nana Kazhiloti, Credentialing Department, WCH

The Bigger Picture: An Industry-Wide Trend, Not Just an Oscar Story

Oscar’s restructuring doesn’t happen in a vacuum. Across the U.S. managed care landscape, insurers are under simultaneous pressure from multiple directions: membership growth that outpaces administrative infrastructure, Medical Loss Ratio (MLR) constraints that cap how much of premium revenue can go to overhead, and post-pandemic profitability normalization after several years of elevated claims costs. For publicly traded and growth-stage insurers alike, administrative margin compression has become a central operational challenge in 2025–2026.

Entity separation — moving network administration into a dedicated management corporation while keeping insurance risk in the licensed carrier — is one of the industry’s preferred structural responses. It allows greater flexibility in contracting, cost allocation, and fee schedule management without triggering the full regulatory review that a merger or acquisition would require. Oscar is not the first insurer to make this move, and it will not be the last. Providers who understand this broader context are better positioned to read between the lines of routine-sounding administrative notices.

The Entity Transition: What Changed and Why It Matters

Effective January 1, 2026, Oscar Health formally transferred network administration and all existing provider contracts from Oscar Insurance Company to Oscar Management Corporation. The move was framed as a routine administrative efficiency measure tied to Oscar’s growing New York membership.

While Oscar’s notice states that “no action is required” and that compensation schedules remain unchanged, providers should not treat this communication as purely ceremonial. When a contract migrates to a new legal entity, the counterparty to any future dispute, appeal, or reimbursement negotiation changes accordingly. The letter explicitly instructs providers to retain it as part of their Agreement with Oscar Health — underscoring its legal standing.

What this means in practice: Update internal records to reflect the new contracting entity. Verify that pending claims, appeal submissions, and prior correspondence are correctly associated with Oscar Management Corporation. Direct questions to providercontracting@hioscar.com.

The Hidden Financial Signal: Is This a Prelude to Rate Compression?

This is the question the notice doesn’t answer — but providers are right to ask it.

Entity separation creates operational flexibility. By moving network administration into a management corporation, Oscar gains the ability to restructure or segment fee schedules with greater agility — without necessarily touching the insurance entity’s statutory obligations. This is architecturally useful if you anticipate needing to move quickly on contracting terms.

Does this mean rate cuts are coming? Not automatically. But entity restructuring of this kind has historically preceded fee schedule reviews at other large insurers, particularly during periods of membership growth when cost-per-member optimization becomes a board-level priority. The timing — early 2026, after a period of rapid Oscar expansion — fits that pattern.

What this means in practice: Monitor Oscar fee schedule communications closely over the next 12–18 months. If you receive a reimbursement change notice, you have 30 days to object in writing and the right to exit the contract on the effective date of the change. That right is real and enforceable — but it expires if you don’t act.

What This Does NOT Mean

Because the framing of this notice invites anxiety, it’s worth being equally precise about what it does not signal.

This transition does not automatically reduce your reimbursement rates. Oscar’s letter explicitly states compensation schedules are unaffected, and any adverse change still requires 90 days’ advance written notice under N.Y. Insurance Law §3217-b. This transition does not suspend or weaken your statutory protections. Every right encoded in Exhibit 7.3 — prompt pay timelines, overpayment recovery limits, termination due process, non-retaliation guarantees — remains fully intact and enforceable regardless of which Oscar entity holds your contract. And this transition does not relieve Oscar of its prompt pay obligations. The 30-day electronic and 45-day paper payment windows under N.Y. Insurance Law §3224 apply to Oscar Management Corporation exactly as they applied to Oscar Insurance Company. The legal entity changed; the law did not.

Claims Timelines: Statutory Floors, Not Negotiable Targets

Exhibit 7.3 codifies Oscar’s obligations under N.Y. Insurance Law §3224. The key numbers: providers have 120 days from date of service to submit claims. Oscar must pay clean electronic claims within 30 days and paper or fax claims within 45 days. If Oscar disputes liability, it must notify you in writing within 30 calendar days, with specific reasons or an information request.

What this means in practice: Payments delayed beyond these windows give you documented legal grounds for escalation — through Oscar’s portal first, then through the New York State Department of Financial Services if unresolved. Timestamp all submissions.

Overpayment Recovery: The 24-Month Rule and Its Exceptions

Oscar generally cannot pursue overpayment recovery more than 24 months after the original payment date, and must provide 30 days’ written notice with full detail before any recovery attempt. Providers have the right to formally challenge.

The critical exception: the 24-month cap disappears if Oscar alleges fraud, intentional misconduct, or “abusive billing” — defined as a pattern of claims inconsistent with sound fiscal or medical practices. This carve-out is broad.

What this means in practice: Providers with concentrated billing in narrow CPT code ranges carry more exposure here. Audit billing patterns proactively and ensure medical necessity documentation is solid before an inquiry arrives.

Termination Rights and Non-Retaliation: The Process Is on Your Side

Oscar cannot terminate a provider without written notice, stated reasons, and the opportunity for a hearing before a panel that includes at least one clinical peer in the same specialty. No termination takes effect earlier than 60 days from receipt of notice. Oscar cannot terminate or non-renew a contract in retaliation for patient advocacy, complaint filing, claim appeals, or government reporting. Any contract clause purporting to waive these rights is void under Section 13.6.

What this means in practice: If you receive a termination notice, the 30-day window to request a hearing is your primary leverage point. Missing it forfeits your right to review entirely.

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Sources

1. Oscar Health, Notice of Entity Expansion, February 10, 2026.
2. Oscar Health, Exhibit 7.3 — New York State Program Requirements, 2026.
3. N.Y. Insurance Law §3224 — Payment of Health Claims. https://www.nysenate.gov/legislation/laws/ISC/3224
4. N.Y. Insurance Law §3224-a — Standards for Prompt, Fair, and Equitable Settlement of Claims.
5. N.Y. Insurance Law §3224-b — Overpayment Recovery.
6. N.Y. Insurance Law §3217-b — Managed Care: Provider Contracts. https://www.nysenate.gov/legislation/laws/ISC/3217-B
7. N.Y. Insurance Law §4803 — Prohibition on Interference with Provider-Patient Relationship.
8. NY State Department of Financial Services — Health Insurance Complaints. https://www.dfs.ny.gov/consumers/health_insurance
9. Oscar Health Provider Portal. https://hioscar.com