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HHS publishes Exchange guidance and draft blueprint

Posted on May 16, 2012 | No Comments

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Key Developments
Implementation Briefs

The US Department of Health and Human Services (HHS) published guidance today on the implementation of the federally-run fallback exchange that the government will run in states that are not ready to operate a state-run exchange. In addition to the higher level operational approach, the paper also discusses how states can partner with HHS to implement selected functions in a Federally-facilitated Exchange (FFE), key policies organized by Exchange function, and how HHS will consult with a variety of stakeholders to implement an FFE. HHS also released a draft blueprint for approval of state-based or state-federal partnership exchanges. State exchanges must be certified by HHS by the beginning of 2013.

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The Center for Consumer Information and Insurance Oversight (CCIIO) issued their Blueprint for Approval of Affordable Health Insurance Marketplaces. This document outlines key steps for states interested in altering their Marketplace configuration for 2015. The blueprint requires states to provide a letter of intent to CCIIO by May 1st and to submit their own Marketplace blueprints by June 1st. The blueprint also reminds states that Marketplace establishment grants will still be available to them through 2015.
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.
According to a Frequently Asked Questions (FAQ) guidance posted by the Center for Consumer Information and Insurance Oversight (CCIIO), states can determine whether health insurance plans qualify for the online health insurance exchange markets and conduct other plan management activities without submitting a "blueprint" application to the Department of Health and Human Services (HHS). The blueprints are applications that must be submitted to HHS in order for states to operate state-based exchanges or to participate in a state partnership exchange under the Affordable Care Act (ACA).
According to a guidance released today by the U.S. Department of Health and Human Services (HHS)'s Center for Consumer Information and Insurance Oversight (CCIIO), states operating State Partnerships Exchanges for plan year 2014 that intend to transition to a State-based Exchange for plan year 2015  have until November 18, 2013 to submit a Declaration Letter and a Blueprint Application to HHS.
Today, the Office of Consumer Information and Insurance Oversight, a division within the Centers for Medicare & Medicaid Services (CMS), released the final version of the approval for state-based health insurance Exchanges. An Exchange is an entity that both facilitates the purchase of Qualified Health Plans (QHP) by qualified individuals and provides for the establishment of a Small Business Health Options Program (SHOP), consistent with provisions under the Affordable Care Act (ACA). Exchanges will provide competitive marketplaces for individuals and small employers to directly compare and purchase private health insurance options based on price, quality, and other factors.
The U.S. Department of Health and Human Services (HHS) awarded another $181 million in health insurance exchange establishment grants yesterday, bringing the total amount allotted to such grants to $1 billion. The six recipients of the grants, Illinois, Nevada, Oregon, South Dakota, Tennessee and Washington, will use the grants to establish Affordable Insurance Exchanges, which will help consumers and small businesses choose a private health insurance plan. These comprehensive health plans will ensure consumers have the same kinds of insurance choices as members of Congress. Including the most recent awards, 34 states and the District of Columbia have received Establishment grants to fund their progress toward building Exchanges. States must indicate by the beginning of 2013 whether they will operate an Exchange on their own or in partnership with the federal government. Otherwise, HHS will fully oversee the establishment of the state's Exchange.
A new report by the Commonwealth Fund, conducted by researchers from Georgetown University's Health Policy Institute, discusses the progress state-based Exchanges (SBE) have made in designing and developing their Exchanges. The report, Implementing the Affordable Care Act: Key Design Decisions for State-Based Exchanges, found many of the SBE will likely exceed requirements placed upon them under the Affordable Care Act (ACA). For instance, several states will be reporting quality data in their individual Exchange in 2014, while others will be offering the employee-choice model in the small business health options program (SHOP) Exchange also for plan year 2014. These findings bolster the claim that states created their Exchanges in a manner that is most conducive to and reflective of the needs of their residents.
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.
A primary goal of the ACA is to increase consumer choice by stimulating market competition among health plans to offer more affordable, value-based options through the new insurance exchanges. The state health insurance exchanges are designed to provide consumers choices among pre-approved health plans that meet certain federal standards ranging from the provision of specific benefits to anti-discriminatory requirements for consumers with pre-existing health conditions. Only plans that meet these standards – the qualified health plans or QHPs – will be allowed to participate in the exchanges. To foster competition, particularly in markets where one insurer holds a significant share, the ACA also requires two QHPs participating in each exchange to be multi–state plans or MSPs. Unlike other QHPs participating...
On May 16, 2012, the United States Department of Health and Human Services issued a Draft Blueprint for Approval of Affordable State-based Exchanges (SBEs) and State Partnership Exchanges (SPEs). HHS also issued General Guidance on Federally Facilitated Exchanges (FFEs). Together, these two documents provide additional implementation information related to the final Exchange regulations issued by HHS on March 27, 2012, (click here for the regulations) which broadly describe the structural and operational requirements for state Exchanges, specify the Exchange approval process, and provide for FFEs in states that do not elect to operate a state Exchange. The newest guidance amplifies on the approval process for both state-based Exchanges (SBEs) and state Partnership Exchanges (SPEs) as a sub-class of FFEs but with...