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Digging in to Benchmark Plan Details
Eager to dig into details about state benchmark plan choices so far? This chart provides key details—with direct links to evidence of coverage documents and CCIIO’s plan summaries—about the plans states have selected or defaulted into. States had until December 26, 2012 to submit comments on the proposed EHB regulations to finalize their benchmark plan decision. For background, see our blog post.
Like all State Refor(u)m research, this chart is a collaborative effort with you, the user. State Refor(u)m captures the health reform comments, documents, and links submitted by health policy thinkers and doers all over the country. And our team periodically supplements, analyzes, and compiles this key content.
Know of something, like an additional evidence of coverage document, we should add to this compilation? Eager to update a fact we've included? Your feedback is central to our ongoing, real-time analytical process, so tell us in a comment below, or email the author with your suggestion. She can be reached at ksheedy@nashp.org.
*Chart updated on March 18, 2013
| State | Recommendation to HHS | Small Group | Largest HMO | State Employee | National FEHBP | Default | Evidence of Coverage | CCIIO Plan Summaries | Pediatric Vision | Pediatric Oral |
|---|---|---|---|---|---|---|---|---|---|---|
| Selection of a benchmark plan whose benefits will largely define "essential health benefits" | HHS Bulletin, FAQ and final regulations defined options from which states could choose a benchmark plan | If a state does not choose a plan, its benchmark is set by default as the largest small group market product in the state's small group market | The Benchmark plan's coverage details and contract with policyholders | Benchmark plan's summary available at CCIIO | HHS requires benchmark plans to meet all 10 essential health benefit categories including pediatric vision and oral health care services. Many existing commercial plans do not offer pediatric vision or pediatric dental, so states are required to choose a supplemental plan that covers these services. | |||||
| AL | Blue Cross Blue Shield of Alabama PPO 320 Plan | X | X | FEDVIP | FEDVIP | |||||
| AK | Premera Blue Cross Blue Shield of Alaska Heritage Select Envoy PPO | X | X1 | FEDVIP | FEDVIP | |||||
| AZ | Arizona Benefit Options EPO Plan, administered by United HealthCare | X | X | X | FEDVIP | FEDVIP | ||||
| AR | HMO Partners, Inc. Open Access POS, 13262AR001 | X | X | X2 | FEDVIP | CHIP | ||||
| CA | Kaiser Foundation Health Plan Small Group HMO 30 ID 40513CA035 | X | X | X | CHIP | |||||
| CO | Kaiser Foundation Health Plan of Colorado Ded HMO 1200D | X | X | X | CHIP | |||||
| CT | ConnectiCare HMO | X | X | X | FEDVIP | CHIP | ||||
| DE | Highmark Blue Cross Blue Shield Delaware Simply Blue EPO 100 500 | X | X | FEDVIP | FEDVIP | |||||
| DC | Group Hospitalization and Medical Services, Inc. BluePreferred PPO | X | X | X | FEDVIP | FEDVIP | ||||
| FL | Blue Cross Blue Shield of Florida, Inc. BlueOptions 5462 PPO | X | X | FEDVIP | FEDVIP | |||||
| GA | Blue Cross Blue Shield of Georgia HMO Urgent Care 60 Copay | X | X | FEDVIP | FEDVIP | |||||
| HI | Hawaii Medical Service Association Preferred Provider Plan 2010 | X | X | X | FEDVIP | CHIP | ||||
| ID | Blue Cross of Idaho Health Service, Inc. Preferred Blue PPO | X | X | FEDVIP | FEDVIP | |||||
| IL | Blue Cross and Blue Shield of Illinois BlueAdvantage PPO | X | X | X | FEDVIP | CHIP | ||||
| IN | Anthem Blue Cross and Blue Shield of Indiana Blue 5 Blue Access PPO Medical Option 6 Rx Option G | X | X | FEDVIP | FEDVIP | |||||
IA | Wellmark Inc. Alliance Select Copayment Plus PPO | X | X | X | FEDVIP | FEDVIP | ||||
KS | Blue Cross and Blue Shield of Kansas Comprehensive Major Medical Blue Choice PPO GF 500 deductible with Rx card | X | X | X | CHIP3 | CHIP3 | ||||
| KY | Anthem Health Plans of Kentucky, Inc. PPO | X | X | X | CHIP | |||||
| LA | Blue Cross and Blue Shield of Louisiana GroupCare PPO | X | X | FEDVIP | FEDVIP | |||||
| ME | Anthem Health Plans of Maine Blue Choice 20 PPO with RX 10 30 50 5 | X | X | FEDVIP | ||||||
| MD | CareFirst BlueChoice HMO HSA Open Access Plan4 | X | X | FEDVIP | CHIP | |||||
MA | Blue Cross and Blue Shield of Massachusetts, Inc. HMO Blue, 2000 Deductible | X | X | X | CHIP | |||||
MI | Priority Health PriorityHMO100 Percent Hospital Services Plan | X | X | X | FEDVIP | CHIP | ||||
| MN | HealthPartners 500 25 Open Access PPO | X | X | FEDVIP | FEDVIP | |||||
| MS | Blue Cross and Blue Shield of Mississippi Network Blue PPO | X | X | X | FEDVIP | CHIP | ||||
| MO | Healthy Alliance Life Insurance Co. (Anthem BCBS) Blue 5 Blue Access PPO Medical Option 4 Rx Option D | X | X | FEDVIP | FEDVIP | |||||
| MT | Blue Cross and Blue Shield of Montana Blue Dimensions PPO | X | X | FEDVIP | FEDVIP | |||||
| NE | Blue Cross and Blue Shield of Nebraska BluePride PPO | X | X | FEDVIP | FEDVIP | |||||
| NV | Health Plan of Nevada Point Of Service Group 1 C XV 500 HCR | X | X | X | FEDVIP | FEDVIP | ||||
| NH | Matthew Thornton Health Plan (Anthem BCBS) HMO Blue New England 25 50 WITH Rx 10 35 30 OOP 2500 | X | X | FEDVIP | FEDVIP | |||||
| NJ | Horizon HMO Access HSA Compatible | X5 | X | FEDVIP | CHIP4 | |||||
| NM | Lovelace Insurance Company Classic PPO | X | X | CHIP | ||||||
| NY | Oxford Health Insurance, Inc. Oxford EPO | X | X | CHIP | ||||||
| NC | Blue Cross and Blue Shield of North Carolina Blue Options PPO | X | X | X | FEDVIP | FEDVIP | ||||
| ND | Sanford Health Plan HMO | X | X | X | CHIP | CHIP | ||||
| OH | Community Insurance Company (Anthem BCBS) Blue 6 Blue Access PPO Medical Option D4 Rx Option G | X | X | FEDVIP | FEDVIP | |||||
| OK | Blue Cross and Blue Shield of Oklahoma BlueOptions PPO RYB05 | X | X | FEDVIP | FEDVIP | |||||
| OR | PacificSource Health Plans PPO Preferred CoDeduct Value 3000 35 70 | X | X | X | FEDVIP | CHIP | ||||
| PA | Aetna Health, Inc. PA POS Cost Sharing 34 1500 Ded | X | X | FEDVIP | ||||||
| RI | Blue Cross and Blue Shield of Rhode Island Vantage Blue PPO | X | X | X | FEDVIP | FEDVIP | ||||
| SC | Blue Cross Blue Shield of South Carolina Business Blue Complete PPO | X | X | X | FEDVIP | FEDVIP | ||||
| SD | Wellmark of South Dakota Blue Select PPO | X | X | FEDVIP | FEDVIP | |||||
| TN | Blue Cross Blue Shield of Tennessee PPO | X | X | FEDVIP | FEDVIP | |||||
| TX | Blue Cross Blue Shield of Texas BestChoice PPO RS26 | X | X | FEDVIP | FEDVIP | |||||
| UT | Public Employee’s Health Program Utah Basic Plus | X | X | X | ||||||
| VT | The Vermont Health Plan, LLC, CDHPHMO | X | X | X | FEDVIP | CHIP | ||||
| VA | Anthem Small Group PPO | X | X | FEDVIP | FEDVIP | |||||
| WA | Regence BlueShield nongrandfathered small group product | X | X | X | FEDVIP | CHIP | ||||
| WV | Highmark Blue Cross Blue Shield West Virginia Super Blue PPO Plus 2000 1000 Ded | X | X | FEDVIP | FEDVIP | |||||
| WI | UnitedHealthcare Insurance Company Choice Plus Definity HSA Plan A92NS | X | X | FEDVIP | FEDVIP | |||||
| WY | Blue Cross Blue Shield of Wyoming Blue Choice Business 1000 80 20 | X | X | FEDVIP | FEDVIP | |||||
| Total | 20 | 5 | 3 | 0 | 23 | 24 | 42 FEDVIP, 2 CHIP, 7 Included | 31 FEDVIP, 19 CHIP, 1 Included | ||
Notes
1Alaska supplemented their plan with FEHBP.
2Arkansas supplemented their plan with FEHBP.
3In their comment letter to HHS on the final interim rule for standards related to essential health benefits, Kansas revised their supplemental pediatric vision and oral plans to the Kansas Children’s Health Insurance Plan (CHIP) benefits.
4Maryland revised its EHB Benchmark Plan selection.
5New Jersey chose the largest HMO plan to serve as their EHB benchmark and designated NJ FamilyCare (CHIP) as the supplemental pediatric oral plan.
Chart produced by: Jade Christie-Maples and Kaitlin Sheedy

Comments
December 13, 2012 by Kaitlin Sheedy
Post evidence of coverage documents, update a fact we've included on the chart, or ask a question here!
December 14, 2012 by Katherine Blair
I would love to hear how states share how they are approaching the issue of "habiltiative benefits" - over 20 states in the proposed rule chart were listed as having habilitative benefits, yet the HHS guidance has repeatedly said habiltiative is not a common coverage category. Are states attempting to define these benefits, or deferring to carriers? If a state has habilitative benefits in its benchmark, what scope do they have?
December 18, 2012 by Chris Koller
Katherine
RI was one of the few states to admit it did not cover habilitave benefits. We have given the following guidance to plans in the form of a draft regulation about how to comply with new aca consumer protections, including ehbs - http://www.ohic.ri.gov/Regulation%2017%20filing%20forms%20and%20rates.php
A key addendum to the reg is a check list to be used by the plans when submitting and by us when reviewing. The check list is not part of the reg so we can update it. In that check list are our specific directions for EHB, including hab services. We have asked the plans to define hab services with the following guidance:
- have evidence-based coverage guidelines for hab services, not scope and duration limits.
- if you can;t do that, submit a memorandum to say why not.
- provide actuarial memorandum demonstrating the estimated costs of hab benefit are not less than estimated cost of rehab benefit in bench mark plan.
We will review submissions and consider
This is an attempt to meet stakeholder feedback which included
- no unlimited habilitative services benefit.
- no arbitrary scope and duration limits,.
No questions from the plans so far or stakeholders - could be because they are swam;ed with other things. It will be interesting to see what they submit.
hope this helps
Chris Koller
December 18, 2012 by Katie trueworthy
In CA we worked with numerous stakeholders to develop a definition for habilitative services, which I've posted below. California believed it was critical for the state to define a uniform definition to be used by carriers and not have each carrier attempt to create a separate definition. Happy to answer any questions.
Katie Trueworthy
Senate Health Committee
Habilitative services" means medically necessary health care services and health care devices that assist an individual in partially or fully acquiring or improving skills and functioning and that are necessary to address a health condition, to the maximum extent practical. These services address the skills and abilities
needed for functioning in interaction with an individual's environment. Examples of health care services that are not habilitative services include, but are not limited to, respite care, day care, recreational care, residential treatment, social services, custodial care, or education services of any kind, including, but not
limited to, vocational training. Habilitative services shall be covered under the same terms and conditions applied to rehabilitative services under the policy.
January 4, 2013 by Dustin Arnette
Has anyone tracked how many states submitted comments or updates to their EHBs to CCIIO? I am aware of MD selecting a new EHB Benchmark, OH submitted a letter on Habilitative Services (http://www.healthtransformation.ohio.gov/Autismservicesv2.aspx), and CO also submitted a comment letter - which also defined Habilitative Services (http://www.getcoveredco.org/COHBE/media/COHBE/PDFs/Federal%20Comms/EHB-C...). Just wondering if there were other comment letters out there.
January 10, 2013 by Jade Christie-Maples
Hi Dustin,
In addition to the letters you mentioned, we have also found letters from Kansas and Arizona that address the issue of habilitative benefits.
The letter from Kansas indicates that because their EHB benchmark has well-defined rehabilitative services, they will require participating plans to offer habilitative services in parity with rehabilitative ones. Kansas expects that this will ensure consistency across plans offered in the state. You can find the letter here: http://www.ksinsurance.org/consumers/healthreform/ehb_hearing_2012/KID_C...
In their comments on the interim final rule, Arizona requested that states be permitted extra time to define habilitative services in their benchmarks. See here for their comments: http://www.statereforum.org/sites/default/files/az_comment_letter_on_ehb...
In addition, New Jersey submitted a comment letter selecting the largest HMO plan in the state to serve as their benchmark. You can find that here: http://www.statereforum.org/sites/default/files/christie_ehb.pdf
I hope this helps. We would love to hear from other states that can share their own comments on the final EHB rule.
January 31, 2013 by Jade Christie-Maples
Arkansas has developed some great materials on the issue of habilitative benefits. Although their conversation is ongoing, here’s their latest presentation and the draft language they’ve developed so far. AR’s Steering Committee approved language in December defining habilitative benefits to be “services provided in order for a person to attain and maintain a skill or function that was never learned or acquired and is due to a disabling condition” including “physical, occupational and speech therapy provided for developmental delay, developmental disability, developmental speech or language disorder, developmental coordination disorder and mixed developmental disorder.”
The Steering Committee has deferred to the Plan Management Committee to further define specific services to be covered under this essential health benefit.
Presentation: http://www.statereforum.org/sites/default/files/ar_habilitativejan2013.pdf
Draft Language: http://www.statereforum.org/sites/default/files/ar_draft-habilitative-se...
February 7, 2013 by Brian Schiefen
Could someone double check the totals at the bottom? I have scrolled up and down several times and not found the "1" in the National FEHBP column. If one column is wrong, others may be as well.
If the chart is maintained as an Excel sheet, you may wish to use a formula to keep the totals accurate. For example =COUNTA(F3:F53) would count non-blank cells, unless your blank cells contain null strings. To count the number of cells containing at least the letter "x" you could use =COUNTIF(F3:F53,"*x*"). A more intricate option would be =SUM(LEN(F3:F53)>0) ; because it is an array formula, you need to hold down shift and ctrl while pressing enter or it will generate an error.
People here seem genuinely appreciative of sound data, so I am confident my comment will be taken in the spirit it is intended, even if it looks like a techie side note.
February 8, 2013 by Kaitlin Sheedy
Hi Brian: Thanks for letting us know! We fixed the totals at the bottom to reflect what is displayed in the chart. Please feel free to offer your feedback any time- we welcome and appreciate it!
March 19, 2013 by Jeanene Harlick
All the information I've read on EHBs notes that states will have to supplement their benchmark plans with categories from other plans if they are missing one of the 10 essential coverage areas. I can't find these supplemental plans anywhere. Have states simply not submitted them yet or am I looking in the wrong places? I am trying to survey benchmark plans' mental health coverage but don't think I can get a true idea of whether there is equitable coverage unless I review supplemental plans as well. If you could help clarify this issue I'd appreciate it! Thanks.
March 20, 2013 by Jade Christie-Maples
Hi Jeanene, Thank you so much for your question. Generally, we have found information on state benchmark decisions and specific evidence of coverage documents on their Insurance Department and/or exchange websites. The specific supplement plans are listed in the CCIIO plan summaries we’ve linked to above. From what we know, only Alaska and Arkansas supplemented the mental health benefit coverage in their benchmark plan. I was able to access Arkansas’s FEHBP supplement for mental health coverage (see page 45, http://hbe.arkansas.gov/FFE/Plan/QC-Federal-EHBP.pdf) You can find all links to their benchmark selection process here: http://hbe.arkansas.gov/FFE/Plan.html
March 25, 2013 by Jerry Rowland
Hi Jade & Kaitlin, Could you please tell me if the ACA final regulations for 2014 will finally eliminate the division between mental health benefits and medical health benefits? In other words, will all health insurance policies be required to provide full mental health benefits in 2014? We have suffered for many years with the lack of (or strong limitations on) mental health insurance benefits here in Texas. Will this unfortunate, but clear division between these medical and mental health benefits finally disappear in 2014?
March 28, 2013 by Ellen Weber
Hi Jerry, The final regulations on Essential Health Benefits require qualified health plans that will be sold through an Exchange and plans that will be sold in the individual and small group market to comply with the Mental Health Parity and Addiction Equity Act. That means that plans must provide mental health and substance use disorder benefits, and they cannot impose limitations on the duration of treatment (number of visits,lengths of stay) or financial requirements (cost sharing) that are more restrictive for these services than for medical services. The Parity Act standards should also require carriers to provide a continuum of services for mental health/substance use disorders that is comparable to medical services, although the federal agencies have not yet issued a final ruling on this "scope of services" question. Coverage for mental health services should improve in Texas. However, I noticed that the Texas benchmark plan includes restrictions on the number of days of care that will be covered for mental health outpatient and inpatient care. It also limits the number of lifetime treatment admissions for addiction treatment. These limitations most likely violate the Parity Act, and health plans should not be able to impose these restrictions. You should contact the Texas insurance department and request that it enforce the Parity Act.
April 3, 2013 by Kenneth Finegold
The January 16, 2013 State Health Official/State Medicaid Director letter re Application of the Mental Health Parity and Addiction Equity Act to Medicaid MCOs, CHIP, and Alternative Benefit (Benchmark) Plans may also be of interest: http://www.medicaid.gov/Federal-Policy-Guidance/downloads/SHO-13-001.pdf.
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