Centers for Medicare & Medicaid Services
Posted on November 29, 2013
In a letter sent to State Medicaid Directors, the Centers for Medicare and Medicaid Services (CMS) stated the agemcy would allow states to use “flat files,” or files with very little information about new Medicaid enrollees, to intermittently count as full applications in terms of enrolling individuals into state Medicaid programs under the Affordable Care Act (ACA). The ACA permits states, if they so choose, to expand their Medicaid population, and provides the opportunity for individuals to enroll in Medicaid through the health insurance Exchanges. Currently, the federal government cannot transfer complete Medicaid applications to states, which prevents states from enrolling their constituents into Medicaid in a timely fashion. CMS is addressing this issue by allowing the “flat files” to count as enrollment applications so that states may ensure these new enrollees have Medicaid coverage by January 2014. This fix is a transitional policy, and states must apply for a waiver in order to use the flat files for enrollment.
Posted on November 26, 2013
In response to changes made by the administration’s new transitional policy, which continues plans slated for cancellation under the Affordable Care Act (ACA), the US Department of Health and Human Services (HHS) issued a proposed rule to modify the health insurance risk pool. The proposed rule, 255 pages in length, outlines changes in payment parameters and oversight for the “triple r”- risk adjustment, risk corridors, and reinsurance.
In addition to changes to the “triple r,” this rule formally announces the administration’s decision to delay annual open enrollment for 2015, which will now be held November 15, 2014 through January 15, 2015. HHS also delayed the Exchange blueprint submission deadline for states choosing to operate their own health insurance marketplace in future years. States applying to create their own Exchange must submit their materials to HHS by June 1st of the year prior to opening the Exchange, and HHS will certify the Exchange by June 15.
Posted on November 22, 2013
The Centers for Medicare and Medicaid Services (CMS) released several sample letters that may be used to notify plan members of their options in regards to the transitional policy announced last week. The transitional policy effectively states that individuals or small businesses currently enrolled in plans that would be cancelled by the Affordable Care Act (ACA) may remain in or re-enroll in these plans. CMS provided three documents concerning this issue: a sample letter to be sent to individuals that have already received a cancellation notice for their coverage, a sample letter to individuals that have yet to receive a cancellation notice, and a document containing standard language that will satisfy the notification requirement under the transitional policy.
Posted on November 14, 2013
A letter written to state insurance commissioners from Gary Cohen, Direct of the Center for Consumer Information and Insurance Oversight (CCIIO), encouraged states to adopt a transitional policy concerning cancellation of health plans as a result of the Affordable Care Act (ACA). The letter states that active plans in the individual and small group markets may be renewed for the 2014 plan year if (1) the plan was in effect as of October 1st, 2013 and (2) the insurance issuer sends a letter to plan members that have or will have their plans terminated. The letter should describe:
- changes in available insurance options;
- how the plan member’s current plan deviates from the market reforms instituted by the ACA (i.e. no coverage of individuals with pre-existing conditions, no guaranteed issuance, etc.);
- the right and ability of a plan member to enroll in a plan through the ACA’s health insurance marketplaces;
- how a plan member may enroll in a new plan through the ACA marketplaces; and
- the ability of the plan member to enroll in another plan outside of the marketplaces that adheres to ACA market reforms.
Posted on October 29, 2013
The Center for Consumer Information and Insurance Oversight (CCIIO), within the Centers for Medicare and Medicaid Services (CMS), published an FAQ concerning the open enrollment period for individuals purchasing qualified health plans (QHPs) under the Affordable Care Act (ACA). The guidance states that individuals will be able to enroll in QHPs throughout the entire enrollment period, which lasts through March 31st, and not be subject to the individual shared responsibility payment. According to the ACA, individuals would have to enroll in a plan by the 15th of each month in order for their QHP coverage to be effective at the start of the following month. Individuals that enrolled in plans after the 15th would not be covered for another two months. The issue pertains to individuals that would enroll in QHPs between February 16th and February 28th of 2014. These individuals would not be covered until April 1st, and would therefore be subject to the minimum essential coverage penalty under the ACA (the minimum essential coverage provision states that an individual must pay a penalty if he or she does not have coverage for more than three consecutive months in a year). This guidance removes that snafu in the law and states that CCIIO will provide additional guidance on the issue in 2014.
Posted on October 24, 2013
Today, the Centers for Medicare and Medicaid Services (CMS) published a final rule concerning financial integrity and oversight for Marketplaces and qualified health plans (QHP). Some of the key components addressed in this rule include: clarifications and amendments to market reform rules, standards for special enrollment periods, and standards for survey vendors that may conduct enrollee satisfaction surveys for QHP issuers. One specific amendment in the rule enables QHP issuers to use a “simplified methodology” in determining cost-sharing reductions for qualifying plan enrollees, which CMS states will protect federal funds and minimize administrative burden.
Posted on October 22, 2013
Yesterday, the Centers for Medicare and Medicaid Services (CMS) issued a Request for Comment (RFC) concerning new exemptions to the individual mandate under the Affordable Care Act (ACA). This particular RFC asks for additional information on the burden experienced by health care sharing ministries, and if such burden would qualify for an exemption from the individual mandate.
Posted on October 16, 2013
The Centers for Medicare and Medicaid Services (CMS) issued a draft application and a corresponding data collection comment request concerning exemptions from the individual mandate. Under the Affordable Care Act (ACA), certain groups of individuals, such as those experiencing financial hardships or those that belong to a religious organization that opposes the use of insurance, are deemed exempt from the individual mandate and are therefore not required to pay the $95 penalty in 2014. This specific draft application, which is for individuals requesting a hardship exemption, is 6 pages in length and requires applicants to provide the type of hardship they are experiencing and their tax information. CMS anticipates that more than 12 million individuals will apply for the individual mandate exemption. The data collection comment request outlines options for states to rely on the Department of Health and Human Services (HHS) to determine eligibility exemptions, and asks the Office of Management and Budget (OMB) to approve the annual information collection requirements associated with the application.
Posted on October 14, 2013
The Centers for Medicare and Medicaid Services (CMS) recently published their “Enrollment Operational Policy and Guidance” concerning Federally-Facilitated Marketplaces (FFM). The guidance, released on October 3rd, stated that enrollments made after October 1st must comply with the provisions in the document. The guidance applies to entities associated with the enrollment process, such as FFM, qualified health plan issuers, and agents and brokers, and describes how these groups are expected to operate in terms of aiding individuals in obtaining health insurance and subsidies. The guidance purports that CMS intends the document to be “living,” and the agency will provide consistent updates and clarification on the provisions therein.
Posted on October 2, 2013
The Centers for Medicare and Medicaid Services (CMS) issued an interim final rule on disproportionate share hospital (DSH) payments. The rule alters when certain hospitals, specifically those with reporting periods that do not align with the fiscal year, will receive Medicare DSH payments. The discrepancy was causing administrative and financial issues for these hospitals, which CMS ultimately determined were not in the best interest of the patient population of these hospitals. The new rule was issued with significant encouragement from the American Hospital Association and Association of Medical Colleges.