Health Insurance

Implementation Briefs

Update: Frequently Asked Questions on Patient Cost-Sharing Under the ACA – Set 12

Categories: Health Insurance, Implementation Update

Posted on May 16, 2013

The ACA contains numerous provisions affecting patient cost-sharing, both generally and in relation to specific services. Some of the provisions (such as those related to preventive services and annual limits on out-of-pocket cost-sharing) apply across multiple coverage markets (i.e., to health insurance products sold in both the individual and group markets as well as to self-insured plans). Other provisions, such as those governing deductibles applicable to the essential health benefit (EHB) package, apply only to those markets that are subject to the EHB requirement, i.e., health plans sold in the individual and small group (under 100 full-time employees) market. In general, the cost-sharing rules exempt grandfathered health plans.

Final Rule: Notice of Benefit and Payment Parameters for 2014

Categories: Health Insurance, Implementation Update

Posted on May 8, 2013

On March 11, 2013, the U.S. Department of Health and Human Services (HHS) released a final rule on the Notice of Benefit and Payment Parameters for 2014. This final rule addresses a variety of issues, including the specific payment parameters for the three premium stabilization programs – the permanent risk adjustment program, the transitional reinsurance program, and the temporary risk corridors program. In addition, the final rule also covers advance payments of the premium tax credit, cost-sharing reductions, and user fees for the federally-facilitated Exchanges, specific requirements related to the federally facilitated Small Business Health Option Program (SHOP), and the medical loss ratio program. This rule finalizes the provisions set forth in HHS’s proposed rule on these topics, December 7, 2012...

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

Categories: Health Insurance, Implementation Update

Posted on May 8, 2013

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...

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

Categories: Health Insurance

Posted on May 1, 2013

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...

Update: Using Medicaid to Provide Premium Assistance for Exchange Coverage

Categories: Health Insurance, Implementation Update

Posted on April 10, 2013

This update to our previous Implementation Brief on states’ option to implement Medicaid coverage by enrolling beneficiaries into Qualified Health Plans sold in Exchanges examines Frequently Answered Questions on Medicaid and Premium Assistance (“FAQ”), released on March 29th by CMS. The FAQ answer some, but not all, questions raised by this approach to implementation of the ACA Medicaid expansion...

Access to Pediatric Oral Health Benefits offered through Health Insurance Exchanges

Categories: Health Insurance

Posted on April 4, 2013

This Implementation Brief examines current Administration policy regarding access to children’s oral health benefits among families who qualify both for Exchange coverage and for advance premium tax credits and cost-sharing reduction assistance. The Brief identifies an emerging set of policy issues that in turn may be creating a policy misalignment between children’s oral health coverage and the premium credits and...

Multi-State Health Plans: The Final Rule

Categories: Health Insurance, Implementation Update

Posted on April 3, 2013

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 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 further foster competition, the ACA also requires two QHPs participating in each exchange to be multi–state plans...

The QHP Certification Process in Federally-Facilitated Exchanges: Network Adequacy and Essential Community Providers

Categories: Health Insurance, Implementation Update

Posted on March 27, 2013

One of the more complex Affordable Care Act implementation questions involves the relationship between health insurance Exchanges and state departments of insurance around the issue of qualified health plan (QHP) certification. This relationship is discussed at some length in federal guidance published on March 1 2013, which offers the federal government’s latest thinking on how this relationship might work in states in which a federally funded Exchange (FFE) is operating, either with or without a Partnership agreement. As of March 2013, an FFE is expected to be operating in...

Update: Contraception Coverage within Required Preventive Services

Categories: Health Insurance, Implementation Update

Posted on March 20, 2013

The ACA requires all individual and non-grandfathered group health plans to cover certain preventive services, including contraceptive services. This is an update to the March 2012 brief on Contraception Coverage within Required Preventive Services, and to the April 2012 update to that brief.

Update: Essential Health Benefits Final Rule

Categories: Health Insurance, Implementation Update, Medicaid and CHIP

Posted on March 13, 2013

On February 25th, 2013, final regulations implementing the essential health benefit (EHB) provisions of the Affordable Care Act were published in the Federal Register (78 Fed. Reg. 12834-12872). The EHB rules, which amend 45 C.F.R., apply to all non-grandfathered individual and small group health plans sold after January 1, 2014, as well as Medicaid benchmark and benchmark-equivalent health plans. The EHB rules also apply to...

Using Medicaid Funds to Buy Qualified Health Plan Coverage for Medicaid Beneficiaries

Categories: Health Insurance, Medicaid and CHIP

Posted on March 7, 2013

On February 28th, 2013, Politico reported that Arkansas Governor Mike Beebe had received approval “to take federal Medicaid expansion money and use it to buy private health coverage for low-income residents through the state’s insurance exchange.” This Implementation Brief explains the legal basis for this decision, as well as the issues that can be expected to arise in using this approach to coverage.

Update: Basic Health Program FAQs

Categories: Health Insurance, Implementation Update, Medicaid and CHIP

Posted on February 27, 2013

On February 6, 2013, the Centers for Medicare and Medicaid Services (CMS) issued a new series of ACA-related Frequently Asked Questions (FAQs). The first two questions address the Basic Health Program (BHP). As described in an earlier Implementation Brief, the BHP was included in the ACA as a special state coverage option for low-income families and individuals. In answer to the question “When will the Basic Health Program be operational?”, CMS replied that the agency does not intend to propose implementing rules until sometime in 2013 and furthermore, that final rules will not be issued until 2014. The status of the Basic Health Program emerged as one of the subjects of a Senate Finance Committee’s ACA oversight hearing on February 14, 2013, during which Senator Maria Cantwell (D-WA), who sponsored the legislative amendment creating the BHP, questioned CCIIO Director Gary Cohen on the timing of BHP guidance.

UPDATE: Federal Health Insurance Marketplaces: A Conversation with CCIIO Director Gary Cohen

Categories: Editor's Comment, Health Insurance, Medicaid and CHIP

Posted on February 7, 2013

This Update begins with a summary of federal policy guidance on health insurance Marketplaces that has been issued to date. It then presents in its entirety an interview with Gary Cohen, conducted by Professor Sara Rosenbaum of GW on January 29, 2013. The Update concludes with some observations about key issues that will arise as implementation of the federal Marketplace proceeds.

UPDATE: When Should Uninsured Family Members of Employees with Access to Affordable Self-Only Employer Coverage Qualify for Premium Tax Credits?

Categories: Health Insurance, Medicaid and CHIP, Tax Policy

Posted on February 1, 2013

As noted in a previous Implementation Brief , the Affordable Care Act (ACA) allows for premium assistance through tax credits for the purchase of family coverage from qualified health plans sold through health insurance marketplaces. To be eligible for tax credits, individuals must not otherwise be “eligible for minimum essential coverage” and must have annual incomes of 100-400 percent of federal poverty level. With regard to individuals who are offered employer-sponsored coverage, the law states that in order to qualify for the premium tax subsidy, the employer-sponsored coverage must be deemed unaffordable, defined by the IRS as an employee contribution requirement for self-only coverage that exceeds 9.5 percent of household income. Although the ACA extends eligibility for assistance (based on the affordability test) to workers’ dependents, the remaining question, as noted in another earlier Brief, was whether uninsured family members of employees with access to affordable self-only employer coverage can qualify for a premium tax credit. The IRS answered that question...

Patient Centered Outcomes Research Institute: Final Rule on Calculation of Fees on Policies and Plans

Categories: Health Insurance, Implementation Update

Posted on January 30, 2013

The Patient-Centered Outcomes Research Institute (PCORI) was established under the Affordable Care Act (ACA) as a non-profit corporation to serve as a resource to patients, providers, purchasers and policymakers in making informed decisions about health outcomes, clinical effectiveness and appropriateness of medical treatments, items and services. The corporation is charged with advancing quality and evidence as to how health conditions can be prevented, diagnosed, treated, monitored and managed through research and evidence synthesis. The primary duties outlined in the ACA include identifying research priorities and setting an agenda for research provided through federal funding. PCORI is authorized to carry out a research project agenda through systematic reviews and...

Update: CMS NPRM on Medicaid, Children’s Health Insurance Program, and Exchanges

Categories: Health Insurance, Implementation Update, Medicaid and CHIP, Rulemaking, Rules, and Guidance

Posted on January 25, 2013

On January 14, 2013, HHS issued a Notice of Proposed Rulemaking (NPRM) whose aim is to address a number of issues that arise at the intersection of the three principal federal “insurance affordability programs” established or modified under the Affordable Care Act (ACA): Medicaid; the Children’s Health Insurance Program (CHIP); and the advance premium tax credits and cost sharing reduction assistance available to individuals who apply for coverage in Exchanges. The proposed rules seeks to more closely align these pathways in several basic respects: the process...

Update: Shared Responsibility for Employers Regarding Health Coverage

Categories: Health Insurance, Implementation Update, Tax Policy

Posted on January 23, 2013

On January 2, 2013, the Department of Treasury issued proposed regulations (78 Fed. Reg. 218) that describe in detail the standards that will be applied in determining which employers are covered by the Affordable Care Act’s “shared responsibility” requirements covering large employers. The proposed rules, which build on earlier guidance issued over the 2011-2012 time period, interpret §4980H of the Internal Revenue Code, as added by the ACA. This section provides...

Transforming Health Care Delivery

Categories: Health Care Quality and Delivery System Reform, Health Information, Health Insurance, Long Term Care, Medicaid and CHIP, Medicare

Posted on January 16, 2013

Experts and stakeholders agree the current health care system is unsustainable. By 2020, health care spending will comprise almost 20% of the gross domestic product. Furthermore, an ever growing body of evidence clearly indicates that the system is not experiencing improvements in quality that are reflective of the cost growth. The Patient Protection and Affordable Care Act (ACA) takes significant strides towards the transformation of the American health care delivery system from a system that rewards volume to a system that rewards quality and value. The programs and initiatives...

Update: Final Medicaid Primary Care Payment Rules

Categories: Health Insurance, Implementation Update, Medicaid and CHIP

Posted on January 3, 2013

On November 6, 2012, the Centers for Medicare and Medicaid Services (CMS) published final rules (77 Fed. Reg. 66670-66701) implementing an Affordable Care Act (ACA) provision whose purpose is to temporarily increase state Medicaid payments for primary care services. The ACA requires that state Medicaid agencies pay for primary care furnished by physicians in 2013 and 2014 at least...

Update to Employer Wellness Programs: Notice of Proposed Rulemaking

Categories: Health Insurance, Implementation Update, Public Health

Posted on December 20, 2012

As described in a previous Implementation Brief, the Health Insurance Portability and Accountability Act of 1996 (HIPAA) generally prohibits group health plans and group health insurance issuers operating in the group health market from discriminating against similarly situated individuals with regard to premiums, benefits or eligibility based on a health factor. HIPAA recognized an exception...

Update: CMS FAQs on Exchanges, Market Reforms and Medicaid

Categories: Health Insurance, Implementation Update, Medicaid and CHIP, Tax Policy

Posted on December 19, 2012

This Update summarizes the CMS Frequently Asked Questions (FAQ) document issued on December 10, 2012.

Update: Health Insurance Reforms and Rate Review

Categories: Health Insurance, Implementation Update, Tax Policy

Posted on December 10, 2012

The Patient Protection and Affordable Care Act (ACA) included health insurance market reforms designed to ensure that individuals and small businesses could not be denied coverage or be charged significantly higher premiums because of an individual’s health status. While some of the market reforms enacted in the ACA were designed to go into effect shortly after enactment (e.g., requiring issuers and employer-sponsored plans to cover adult children up to age 26 on a parent’s health plan, and limiting pre-existing condition exclusions) the most sweeping reforms...

ACA Policy Implementation: A Snapshot of Key Developments and What Lies Ahead

Categories: Health Insurance, Implementation Update, Medicaid and CHIP, Medicare, Tax Policy

Posted on December 5, 2012

Beginning January 1, 2014, millions of previously uninsured individuals will gain access to health insurance coverage under the Affordable Care Act (ACA). On November 20, 2012, the Obama Administration proposed a series of regulations that move the nation significantly toward full implementation. These proposed rules will be analyzed at greater length in coming GPS Implementation Brief updates. In the meantime, this overview summarizes the major federal implementation matters that the Administration has recently released or is expected to address in policy or program implementation in the coming weeks and months as the 2014 full implementation date approaches. Together, these matters address...

Essential Health Benefits Update: Proposed Regulations Implementing the ACA; and Application of the Proposed EHB Regulations to Medicaid Benchmark Plans

Categories: Health Insurance, Implementation Update, Medicaid and CHIP

Posted on November 29, 2012

On November 26, 2012, the Obama Administration published a series of proposed rules implementing many of the Affordable Care Act’s (ACA) most important insurance reforms, including Health Insurance Market Rules and Rate Review (77 Fed. Reg. 70584), Nondiscriminatory Wellness Programs in Group Health Plans (77 Fed. Reg. 70620), and Standards Related to Essential Health Benefits, Actuarial Value, and Accreditation (77 Fed. Reg. 70644). In addition, the Administration issued informal guidance that add to and amplify on the provisions of the proposed rules. This Implementation Brief Update examines the proposed rule implementing the Act’s essential health benefits...

When Should Uninsured Family Members of Employees with Access to Affordable Self-Only Employer Coverage Qualify for Premium Tax Credits?

Categories: Health Insurance, Tax Policy

Posted on October 3, 2012

This Implementation Brief on premium tax credits examines the question of how the Affordable Care Act (ACA or the Act) addresses the problem that arises when low- and moderate-income employees have affordable “self-only” employer coverage, but face prohibitively high costs for family coverage, well beyond levels considered “affordable” under the Act. Coverage for a full family is extremely expensive: according to the Kaiser Family Foundation, the average 2012 cost of family coverage approaches $16,000, placing unsubsidized family benefits beyond the reach of all but affluent families. Kaiser further reports that while...

Update: Final Blueprint for Approval of Affordable State-based and State Partnership Insurance Exchanges

Categories: Health Insurance, Implementation Update

Posted on September 14, 2012

The Affordable Care Act (ACA) establishes Affordable Insurance Exchanges, which are entities that facilitate the purchase of Qualified Health Plans (QHP) and provide for the establishment of the Small Business Health Options Program (SHOP). Previous GPS Implementation Briefs have covered these topics here and here.

Update: Student Health Insurance Coverage Final Rule

Categories: Health Insurance, Implementation Update

Posted on August 22, 2012

By Lara Cartwright-Smith Background On March 21, 2012, the Centers for Medicare and Medicaid Services (CMS), part of the Department of Health and Human Services (HHS), published a final rule [1]setting forth requirements for student health insurance coverage. The rule codifies the proposed rule that CMS issued in February 2011.[2] An estimated 1.1-1.5 million students [...]

Premium Tax Credits Offered Through State Health Insurance Exchanges that are Federally Facilitated

Categories: Health Insurance, Implementation Update

Posted on August 2, 2012

Previous updates have summarized final IRS regulations implementing provisions of the Affordable Care Act that provide premium tax credits to help low- and moderate-income individuals and families buy affordable health insurance through State health insurance Exchanges. The IRS regulations provide that premium assistance tax credits are available to all eligible state residents, regardless of whether their state Exchange is state-operated or federally facilitated. This Update examines a dispute that that has arisen regarding the availability of premium assistance tax credits in federally facilitated state Exchanges.

Update: Financial Alignment Demonstrations for Dual Eligible Individuals

Categories: Health Care Quality and Delivery System Reform, Health Insurance, Long Term Care, Medicaid and CHIP, Medicare

Posted on July 18, 2012

The Affordable Care Act (ACA) included a number of provisions designed to improve the delivery of health and long-term care support services for individuals who are eligible for and enrolled in both the Medicare and Medicaid programs, commonly referred to as “dual eligible.” An earlier Health Reform GPS Implementation Brief outlined these changes. Among the provisions identified in the Brief was new demonstration authority provided to the Department of Health and Human Services (HHS) to permit states to waive certain provisions of Medicare law to better coordinate care for dual eligibles, new grant funding available to as many as 15 states to plan and implement integrated programs of care for dual eligibles, and the release of a July 11 State Medicaid Director (SMD) Letter providing preliminary guidance to states on demonstration models designed to improve care coordination for dual eligibles, including both capitated and fee-for-service models. This Brief provides an update on the financial alignment model outlined in the SMD letter, with a focus on subsequent guidance to states and health plans seeking to participate in capitated demonstrations. This demonstration is being followed closely at the federal level, and both...

A Closer Look at the Medicaid Holding in NFIB v Sebelius: Key Implementation Questions

Categories: Health Insurance, Judiciary, Legal Challenges, Medicaid and CHIP, Tax Policy

Posted on July 3, 2012

In NFIB v Sebelius the United States Supreme Court upheld the constitutionality of the Patient Protection and Affordable Care Act (ACA or the Act). At the same time, the decision adds a new dimension to the implementation of §2001(a) of the Act, which establishes expanded Medicaid eligibility for certain low-income people. This Implementation Brief begins with a discussion of exactly what the Court held in its Medicaid ruling. It then discusses the significance of the majority conclusion, as well as the key implementation questions that arise in the wake of this opinion.

Summary of the U.S. Supreme Court decision in the case of National Federation of Independent Businesses et al. v. Sebelius, Secretary of Health and Human Services, et al.

Categories: Health Insurance, Judiciary, Legal Challenges, Medicaid and CHIP, Tax Policy

Posted on June 28, 2012

The Supreme Court handed down its long-awaited ruling in the case of National Federation of Independent Businesses et al. v. Sebelius, Secretary of Health and Human Services, et al., upholding the individual requirement to maintain insurance coverage as a reasonable exercise of Congress’s taxing and spending authority and also upholding the constitutionality of the Medicaid coverage expansion. In a surprise coalition, Chief Justice Roberts was joined in his majority opinion by Justices Stephen Breyer, Ruth Bader Ginsburg, Sonia Sotomayor and Elena Kagan. The summary below describes the majority opinion, the concurring opinion (authored by Justice Ginsburg), and the dissenting opinion (written by Justice Scalia). Because the Court upheld the individual mandate, it never reached...

Update: Health Insurance Premium Tax Credit Final Regulations

Categories: Health Insurance, Implementation Update, Tax Policy

Posted on June 22, 2012

On May 18, 2012, the Department of Treasury (Treasury) issued final regulations on the health insurance premium tax credits enacted by the Patient Protection and Affordable Care Act (ACA). The final regulations, which took effect May 23, 2012, contain amendments to the Income Tax Regulations (26 CFR part 1) and address several issues noted in the proposed regulations (NPRM) issued by the Treasury on August 17, 2011. The refundable premium tax credits were created to help make the purchase of health insurance through the health insurance Exchanges more affordable for low- to middle-income individuals ineligible for Medicaid and without affordable ...

Essential Benefits Update: Data Collection Standards

Categories: Health Insurance, Implementation Update

Posted on June 15, 2012

On June 5, 2012 the United States Department of Health and Human Services (HHS) published a proposed rule (77 FR 33133-33142) that would establish data collection standards for health insurance issuers as part of the Department’s implementation of the Affordable Care Act’s (ACA) essential health benefit provisions. Comments will be accepted until 5:00 p.m. on July 5, 2012. Under the ACA, as of January 1, 2014 all health insurers selling policies in the individual and small group...

Multi-State Health Plans

Categories: Health Insurance, Medicaid and CHIP

Posted on June 7, 2012

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...

Update: Draft Blueprint for Approval of Affordable State-based and State Partnership Insurance Exchanges, General Guidance on Federally-facilitated Exchanges

Categories: Health Insurance, Implementation Update

Posted on May 25, 2012

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...

Update: Medical Loss Ratio Requirements

Categories: Health Insurance, Implementation Update

Posted on May 15, 2012

On May 11, 2012, the United States Department of Health and Human Services (HHS) issued a final rule that revises previous medical loss ratio (MLR) rules to establish consumer notification requirements with which insurers must comply when meeting applicable MLR requirements. In a previous December, 2011 final rule governing other aspects of the MLR amendments, HHS had required notification only when insurers did not ...

Update: Essential Health Benefits FAQs

Categories: Health Insurance, Implementation Update

Posted on May 9, 2012

In February 2012, CMS issued a supplemental document entitled Frequently Asked Questions on Essential Health Benefits Bulletin. This supplement to the December 16th Bulletin provides answers to 22 questions arising from the December 16th Bulletin itself. Highlights are as follows:

Contraception Coverage under the ACA’s Preventive Services Coverage Requirements, and Employer Implementation: An Update

Categories: Health Insurance, Implementation Update, Public Health

Posted on April 20, 2012

This update to our March 2012 implementation brief reviews recent implementation efforts by the Administration in connection with coverage of contraceptives as a required element of required preventive services for all individual and (non-grandfathered) group health plans under the Affordable Care Act. The earlier brief reviewed the Administration’s final rules defining the scope of contraception coverage, as well as the scope of the religious exemption that would apply to employers that seek an exemption from this coverage requirement. Reflecting prior law on this matter, the final rule preserved...

Administrative Simplification: Adoption of Operating Rules for Health Plan Eligibility and Health Care Claim Status Transactions

Categories: Health Care Quality and Delivery System Reform, Health Information, Health Insurance, Implementation Update

Posted on April 13, 2012

On July 8, 2011 the Secretary of the Department of Health and Human Services (HHS) issued an Interim Final Rule with Comment Period (IFR) regarding the operating rules for two types of HIPAA transactions: eligibility for a health plan and health care claim status. The rules are in response to Section 1104 of the Affordable Care Act (ACA), which directed the Secretary to adopt certain operating rules for transactions to enable electronic health information exchange and create greater uniformity in the transmission of health information. The ACA defines operating rules as...

Update on the Final Rule: Standards Related to Reinsurance, Risk Corridors and Risk Adjustment

Categories: Health Insurance, Implementation Update

Posted on April 4, 2012

The reinsurance, risk corridor and risk adjustment programs, established under the ACA at sections 1341, 1342 and 1343, respectively, were developed to mitigate possible health insurance adverse selection and to maintain stable premiums in the individual and small group markets as implementation of the ACA’s insurance market reforms and health insurance Exchanges begin in 2014. Under ACA section 1341, each state must establish a temporary reinsurance program for years 2014-2016 to help stabilize premiums for coverage of high-risk individuals in the private market. Section 1342 of the ACA requires the HHS Secretary to establish a temporary risk corridor program...