A project of the George Washington University's Hirsh Health Law and Policy Program and the Robert Wood Johnson Foundation

Health Insurance

GAO finds Exchange development lagging behind

Posted on June 19, 2013

Two reports issued by the Government Accountability Office (GAO) indicate that substantial progress remains in the establishment of the individual and small group health insurance Exchanges, two key components of the Affordable Care Act (ACA). The GAO report focusing on Small Business Health Options Program (SHOP) Exchanges purports that many of the central aspects of the federally-facilitated SHOP Exchanges remain to be completed, including eligibility and enrollment, plan management, and consumer assistance. According to the report, 44% of the key activities the Centers for Medicare and Medicaid Services (CMS) intended to be completed by March 31st, 2013 were behind schedule. Furthermore, the continually evolving role that CMS plays in SHOP development presents a challenge for the agency to meet subsequent deadlines, several of which are very close to the roll out date.

Similar to the SHOP Exchange, CMS must still work to develop important aspects of the federally-facilitated individual health insurance Exchanges. One important task that has yet to be completed is the testing of the federal data hub with state and federal partners. According to this GAO report, CMS is still in the process of certifying qualified health plans (QHP) and publicizing this information on Exchange websites. CMS has also delayed Navigator funding by 2 months, which has impacted training activities. GAO reported that CMS has completed risk assessment for potential issues associated with the federal data hub. CMS has also been interacting with states to create contingency plans to facilitate successful Exchange implementation prior to the October 1st enrollment period.

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HHS proposed rule covers a slew of ACA provisions

Posted on June 14, 2013

Today, the US Department of Health and Human Services released a proposed rule addressing various facets of the Affordable Care Act (ACA). The 253 page document expands upon guidance previously released to states and stakeholders, covering topics ranging from financial integrity and additional oversight of Exchanges to options available under the Small Business Health Options Program (SHOP). Key provisions provided in the proposed rule include:

  • Qualified health plans must accept a wide variety of payment options for premiums. A recent Jackson Hewitt study found a large number of uninsured Americans lack bank accounts, and restrictive payment policies excluding money orders and prepaid debit cards would impede the ability of these uninsured Americans to gain insurance access.
  • Additional guidance was provided for federally-facilitated Exchange (FFE) states that choose to operate their own SHOP market while the federal government maintains oversight of their individual market, known as the Utah plan. The proposed rule states that data sharing requirements between SHOP and individual markets do not apply in these arrangements. Additionally, states operating their own SHOP Exchange can have their own set of Navigators, separate from the individual market, that perform outreach to small businesses.

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Urban Institute examines state roles in FFE

Posted on June 14, 2013

A new report published by Urban Institute describes the different roles states are playing in their respective federally-facilitated Exchanges (FFE). The Affordable Care Act (ACA) requires every state to host an online individual and small group insurance market, and states that elected not to set up their own Exchange defaulted to FFE. State-Level Progress in Implementation of Federally Facilitated Exchanges, funded by the Robert Wood Johnson Foundation, discusses three case studies of states that are implementing FFE, including the various responsibilities each state has undertaken and the challenges they are facing. Several states, for instance, are playing active roles in the development of their respective Exchanges, while one state is significantly behind as a result of political and administrative setback.

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CRS report explains ACA premium tax credits

Posted on June 11, 2013

The Congressional Research Service (CRS) published a new report demystifying how individuals may qualify for premium tax credits to help offset the costs of obtaining insurance through Exchanges. Health Insurance Exchanges Under the Patient Protection and Affordable Care Act (ACA) outlines the requirements for tax credit eligibility, such as having a household income between 100-400% of the federal poverty level. The report also details how the US Department of Treasury (DoT) will send monthly premiums to insurance companies on behalf of enrollees receiving the tax credit. Tax credits are advanceable and refundable, meaning receipt of the credit will coincide with the time at which monthly premiums are due. Furthermore, each Exchange is responsible for determining tax credit eligibility and the appropriate credit amount for qualifying individuals.

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Interview of Phyllis Borzi, Assistant Secretary of Labor of the Employee Benefits Security Administration (EBSA), United States Department of Labor

Posted on June 11, 2013

Recently, Sara Rosenbaum, the Hirsh Professor of Health Law and Policy at the GW Department of Health Policy, had an opportunity to interview Phyllis Borzi, the federal official in charge of overseeing the Employee Benefits Security Administration (EBSA), for Health Reform GPS. EBSA is an agency of the United States Department of Labor responsible for administering, regulating and enforcing the provisions of Title I of the Employee Retirement Income Security Act of 1974 (ERISA), and the agency is playing an important role in the implementation of the Affordable Care Act….

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GWU analysis finds habilitative services under the ACA face uncertainties

Posted on June 7, 2013

A new analysis from George Washington University’s Sara Rosenbaum found that habilitative services will be uncertain during the initial implementation of the Affordable Care Act (ACA). The analysis, commissioned by the The Lucile Packard Foundation for Children’s Health, discusses the implications of the federal government in permitting health plans to both define the parameters of coverage and also, to potentially scale back coverage for habilitative services in favor of broader coverage for rehabilitation services. Many parents of children with developmental disabilities have trouble getting insurance coverage for habilitative services which can help their children keep, learn or improve their skills and daily functioning. The discretion given to health plans to both define the habilitative services benefit and pursue substitution practices in the absence of state requirements to the contrary raises important issues for individuals and families, as well as for providers of critically important services related to the treatment and management of developmental disabilities.

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Health Affairs estimates demograhic and geographic information of individuals still uninsured after ACA implementation

Posted on June 7, 2013

A recent post from Health Affairs estimates that 30 million Americans will still not have insurance coverage by 2016, well beyond the implementation of the Affordable Care Act’s (ACA) key provisions. The Uninsured After Implementation Of The Affordable Care Act: A Demographic And Geographic Analysis characterized states based upon their proclivity for expanding Medicaid: completely undeclared, leaning toward expansion, or leaning away from expansion. Using data from the Census Bureau’s 2012 Current Population Survey, the researchers found that 29.8 million people would remain uninsured if all undeclared states opt-in to expansion, while 31 million would remain uninsured if all undeclared states chose to opt-out of expansion. Additionally, researchers found that 80% of those remaining uninsured would be US citizens in either scenario.

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DC releases Exchange rates

Posted on June 7, 2013

Four carriers submitted proposed rates for health insurance plans that will be available on the DC Health Benefits Exchange. Aetna, CareFirst BlueCross Blue Shield, Kaiser Permanente, and United HealthCare will collectively offer around 300 plans on DC’s Exchange for plan year 2014.

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GAO report documents Exchange challenges

Posted on June 4, 2013

A recent report released by the Government Accountability Office (GAO) analyzed the progress of implementing the Affordable Care Act’s (ACA) state-based and partnership Exchanges in six states and DC. GAO found that the greatest challenges to achieving complete implementation by October 1, 2103 lie in IT-related work and financing. Several of the states in the study began working on the IT component of their Exchange prior to the release of federal guidelines, meaning significant changes to IT systems may be necessary in the future. Incomplete information on the federal data hub requirements has also hindered full development of several state IT systems. GAO reported that uncertainties associated with the 2014 enrollment numbers make finances very difficult to estimate. States have also employed several different methods to obtain operating funds for 2015. For instance, Oregon will charge an administrative fee of up to 5% of premiums, based upon the number of individuals that enroll in the Exchange. Nevada, however, will charge between $7.13 and $7.78 per member per month, which will be factored into enrollee’s premiums.

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White House memo describes choices and competition in Exchanges

Posted on June 4, 2013

The White House recently released a memo detailing health plan competition and choices anticipated to be available under the Affordable Care Act’s (ACA) health insurance Exchanges. According to the memo, 75% of states with federally-facilitated insurance markets will have at least one new insurance carrier enter their market. The White House memo also reported that 90% of target enrollees will be able to select plans offered by a minimum of five insurance companies. These findings were compared to the current individual insurance market, where two or fewer insurance companies control the market in most states. The memo confirms that state-specific rates will not be released for federally-facilitated Exchanges until September.

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