Implementation Brief Interim Final Rule: Alternative Approaches to Cost-Sharing Reduction Payment and Risk Corridor Calculations

Posted on May 8, 2013 | No Public Comments

The temporary risk corridors program allows the federal government to share a QHP’s profits or losses among other QHP issuers due to inaccurate rate setting inside the Exchanges from 2014-2016. To determine whether a QHP issuer has inaccurately set premium rates that lead to an unjustified profit or loss, a QHP’s “allowable costs” must be calculated per the requirements in the Premium Stabilization Rule. The IFR modifies the definition of “allowable costs” such that a QHP’s allowable costs are to be determined based on its pro-rata share of the QHP issuer’s incurred claims for all non-grandfathered health plans within a state, and allocated to the QHP based on premiums earned by the issuer in the market…

Continue Reading »

CCIIO issues agent and broker guidance

Posted on May 2, 2013 | No Public Comments

The Center for Consumer Information and Insurance Oversight (CCIIO) released new guidance detailing the roles of agents, brokers and web-brokers in the health insurance Exchanges. The letter claims that State-Based Exchanges may establish their own regulations on the amount insurers can pay brokers, while Federally-Facilitated Exchanges, which also includes State-Partnership Exchanges, will not create commission schedules or pay commission directly to the brokers. CCIIO also purported that they will re-evaluate the requirement that brokers receive the same compensation for selling plans outside of the Exchanges as they would for selling qualified health plans (QHP). Brokers are anticipated to play a role in educating consumers entering into the Exchange, and the Centers for Medicare and Medicaid Services (CMS) will be responsible for registering and training agents and brokers to help consumers in the QHP selection process. States, however, will retain the authority to license and regulate brokers and agents.

Continue Reading »

Medicaid expansion allows for coordination between CMS and HRSA

Posted on May 2, 2013 | No Public Comments

The Centers for Medicare and Medicaid Services (CMS) and Health Resources and Services Administration (HRSA) released a joint information bulletin detailing the opportunity to coordinate care between Medicaid and the Ryan White HIV/AIDS Program. The expansion of Medicaid under the Affordable Care Act (ACA) will provide health care access to many people living with HIV/AIDS, therefore necessitating the need for CMS and HRSA to ensure that Medicaid and Ryan White HIV/AIDS programs are poised to collaborate and coordinate care for this population. The two federal agencies will offer webinars and training in the following areas: eligibility, enrollment, essential community providers, managed care practices, and integrated care models for those living with HIV/AIDS.

Continue Reading »

Implementation Brief Sub-Regulatory Guidance Regarding Age Curves, Geographical Rating Areas and State Reporting

Posted on May 1, 2013 | No Public Comments

This Age Curve portion of the sub-regulatory guidance reminds states that in the absence of a state-established and HHS-approved uniform age rating curve for the purpose of age rating in the individual and small group markets, a federal default standard will apply. The statute and final rule require that the premium rate charged by an issuer in the individual and small group market (for non-grandfathered plans) may vary by age, but not by more than a 3:1 ratio for adults. Moreover, the final rule defines, and the sub-regulatory guidance reiterates, the standard age bands for insurance rating purposes as follows…

Continue Reading »

IRS releases NPRM on employer coverage and tax credits

Posted on April 30, 2013 | No Public Comments

The Internal Revenue Service (IRS) issued a proposed rule discussing the minimum value of employer-sponsored health coverage and the ability of employees to receive premium assistance tax credits. According to the proposed rule, IRS states that the minimum value would be determined by dividing the cost of certain benefits to the standard population by the cost of all benefits, including employee cost-sharing and plan payments, and converting that value to a percentage. Several values, such as the amount contributed by employer’s to health savings accounts, will be considered in determining the employer’s share of costs. However, IRS has also proposed that employer contributions to wellness incentive programs does not count toward health plan minimum value. Additionally, the proposed rule also states that employee-sponsored large group plans are not beholden to every essential health benefit category (EHB), nor must they design their plans to mimic the EHB standards that apply to qualified health plans offered in the Exchange. Adherence to the minimum value requirements will prevent employers from paying the employee shared responsibility payment penalties and will render their employees ineligible for premium assistance tax credits in the Exchange.

Continue Reading »

IRS and EBSA issue next set of ACA FAQs

Posted on April 30, 2013 | No Public Comments

In the 15th set of Affordable Care Act (ACA) FAQs, the Internal Revenue Service (IRS) and the Employee Benefit Security Administration (EBSA) answer questions posed by the public and stakeholders to demystify the implementation of various components of the ACA. This particular set discusses annual limit waivers, stating that an alteration to a health plan or policy year will not impact the expiration of an annual limit waiver. The FAQs also indicate that IRS, EBSA and the US Department of Health and Human Services (HHS) will not issue guidance on provider nondiscrimination prior to January 1st, 2014, because the statutory language on the topic is “self-implementing.” In regards to transparency reporting, the FAQs clarify that plans are not beholden to the transparency provisions of the ACA until the plans have been certified as a qualified health plan (QHP) for one benefit year.

Continue Reading »

Brookings proposes reforms to save hundreds of billions in health care

Posted on April 30, 2013 | No Public Comments

The Brookings Institution recently released a study that indicates how value-based payments and small, conscientious quality improvements to both the private and public insurance sectors can significantly reduce health care costs in the future. Bending the Cure: Person-Centered Health Care Reform, describes how such changes could save the federal government $300 billion over the next 10 years and more than $1 trillion over the next 20 years. Brookings finds that moving to patient-centered care is the ultimate means by which future cost savings can be achieved. For a specific example, the study proposes that Medicare should move away from the fee-for-service model and embrace comprehensive payment organizations.

Continue Reading »

HHS releases shorter Exchange enrollment application forms

Posted on April 30, 2013 | No Public Comments

In response to the comments received on the length and complexity of the 21-page health insurance application draft, the US Department of Health and Human Services (HHS) has shaved down the application and released their second iteration this morning. Under the Affordable Care Act’s (ACA) individual mandate, most Americans are required to have insurance by January 1st, 2014. The new application released by HHS is designed to make the enrollment process more streamlined and simple. Individuals wishing to enroll into the Exchange will submit a 5-page document entitled “Application for Health Coverage and Help Paying Costs (Short Form).” The family application, “Application for Health Coverage and Help Paying Costs” comes in at 12-pages in length. HHS has also provided a 5-page application titled “Application for Health Coverage” for anyone wishing to enter the Exchange, but is unsure of their eligibility.

Continue Reading »

CMS extends QHP application deadline

Posted on April 29, 2013 | No Public Comments

Today, the Centers for Medicare and Medicaid Service (CMS) announced a 3-day extension for insurers submitting a qualified health plan (QHP) on the Federally-Facilitated Exchanges (FFE). Insurers will have until May 3rd at 8:00 pm, after which CMS will provide the opportunity for a 3-day Limited Correction Window. The window will permit insurers to make minor application adjustments deemed appropriate by CMS.

Continue Reading »

CCIIO releases FAQ on market reforms

Posted on April 29, 2013 | No Public Comments

The Center for Consumer Information and Insurance Oversight (CCIIO) released a set of eight questions on implementation of the Affordable Care Act (ACA). Specifically, this guidance clarifies the limitation provided in the Market Rule final rule stating that a plan issuer may have one geographic rating factor for each approved geographic rating area per single risk pool in a given state. The following topics are addressed in the FAQ to expand upon the meaning of this limitation:

• Withdrawal of non-grandfathered business
• Maintenance of alternative mechanisms
• Geographic rating areas
• Definition of association coverage
• Premium adjustment when coverage becomes secondary to Medicare

Issuers submitting plans to the federally-facilitated Exchanges may make necessary changes to their plans in order to comply with this new guidance.

Continue Reading »