Exchange Regulations/Guidance
We invite everyone—state officials, experts, interest groups, consumer advocates, and other stakeholders—to submit questions, observations, analysis, and any early thoughts about the final Exchange regulations here. We will also post links to news articles, blog posts, press releases, draft analysis and other helpful materials.
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Colorado
Hello, does anyone know if the exchange will list a plan's taxes and fees along with the premium amount?
Is this a state by state decision? I cannot find anything on this. Any help is much appreciated!
Virginia
Trying to find some clarity on coordination of filing on the FFE for a QHP that is embedding an endorsed dental carriers plan into the QHP...is there guidance on whether the QHP should file the dental portion's policy, and then what does the dental plan need to file? Are there any resources out there for this?
Texas
From my understanding… If a QHP is planning on embedding the pediatric dental EHB as part of their medical policy, then there would be no separate filings for pediatric dental. As of now, the FFM is not allowing bundled medical and dental policies, so you would file the medical policy the same whether it has pediatric dental or not. If you are filing a separate dental policy than that policy would go through filing forms which are taken from the medical forms but modified to be dental specific, whether through SERFF or HIOS.
Following is from pg 32 of the 4/5/13 CCIIO Affordable Exchanges Guidance, “Additionally, the FFE will not have the capacity to display dental benefits of a QHP as a separate or severable benefit, for example where an issuer offers both health plans and stand-alone dental plans and wishes to “bundle” them in the plan compare website. In order to be displayed on the Exchange website, dental benefits must either be offered as part of a comprehensive medical QHP (either directly by the health insurance issuer or through contract with a dental plan issuer) or offered separately through a stand-alone dental plan.”
Link to the Guidance: http://cciio.cms.gov/resources/regulations/Files/2014_Letter_to_Issuers_...
Virginia
Thank you Kris.
District of Columbia
On November 30, 2012, OPM released guidance related to the Multi-State Plan Program- a program through which issuers will offer at least two multi-state plans in each exchange.
District of Columbia
On August 14, 2012, CCIIO released the final version of the exchange blueprint, which states must submit by November 16, 2012, if they plan to operate a state exchange or participate in a partnership exchange.
Florida
Will states require some type of contract with the QHP, or in the case of a TPA on behalf of the QHP, a contract to enter into the HIX, and hold disussions with the appropriate contact people within that States HIX?
District of Columbia
Hi Jennifer-
It seems like the requirement to contract will vary from state to state. Exchanges are required to certify plans, but they are given flexibility to go beyond federal requirements. States that pursue active purchasing may use contracts as part of their strategy to promote certain goals, such as quality, affordability, etc. Many states are still working through issues related to QHP certification and active purchasing, so it should become more clear as those decisions are finalized.
Florida
We are hearing conflicting information regarding the Unique Identifier for Subscribers, has there been a final rule on this matter? If so, what was the determination and where can I find that document?
District of Columbia
Hi Jennifer-
It looks like HHS released guidance back in April on Unique Health Plan Identifiers. I've attached the proposed rule below.
Florida
Thank you, Rachel--I do see where it pertains to Health Plans and TPA's, but possibly missing the Subscriber unique ID number? That will be critical to know for us moving forward as we build out systems.
District of Columbia
Hi Jennifer-
It looks like, according to the guidance, that the Secretary has not adopted a standard patient identifier.
Virginia
Enroll America submitted these comments on the interim final exchange establishment regulations. They address issues related to the role of agents and brokers in exchange eligibility and enrollment, coordination between exchanges and agencies administering Medicaid and CHIP, and timeliness standards for exchange eligibility determinations.
District of Columbia
Tennessee recently released a comprehensive summary of the major changes in the regulation that impact their state. It also includes a series of detailed questions for CCIIO/CMS for clarification on issues such as eligibility determinations, enrollment periods and small group definitions.
District of Columbia
On March 12, 2012, HHS released final rules (with some sections classified as interim final rules) related to: establishment of exchanges, certification qualified health plans (QHPs), SHOP and the navigator program. On March 16, 2012, HHS released final rules on standards related to reinsurance, risk corridors, and risk adjustment.
Wisconsin
The State of Wisconsin submitted the following comments on the proposed federal rules:
CMS-9974-P: Exchange Functions in the Individual Market, Eligibility Determination; Standards for Employers
REG-131491-10: Health Insurance Premium Tax Credit
Wisconsin
The State of Wisconsin submitted the following comments on the proposed federal rules CMS-9989-P Establishment of Exchanges and Qualified Health Plans.
District of Columbia
Here are comments from the National Health Law Program.
District of Columbia
The State of Utah submitted the following comments to the federal government on the proposed federal rules on the implementation of exchanges.
District of Columbia
The Georgetown Center for Children and Families plans to submit the following comments on the July NPRM. In general, we'd like to see more robust federal standards in a number of areas, including preventing conflict of interest on governing boards, a requirement that exchanges conduct needs assessments for consumer assistance and navigator functions, and a process for monitoring and assuring provider network adequacy. And much more!
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