On August 31, 2016 the Centers for Medicare and Medicaid Services (CMS) released a draft list of essential community providers (ECPs), which can be used by insurers seeking to comply with the ECP requirements that apply to qualified health plans (QHPs).
ECPs are providers that serve predominantly low-income, medically underserved individuals. For 2017, QHPs must contract with 30 percent of available ECPs in their service area, offer contracts in good faith to all Indian health providers in their service area, and offer contracts in good faith to at least one ECP in each of six categories of ECPs (family planning providers, federally qualified health centers, hospitals, Indian health care providers, Ryan White providers, and “other” ECPs) to be in compliance with ECP requirements. Requirements for 2018 are not yet available, but are likely going to be similar.
The draft list is non-final. CMS has posted at its website a petition that can be used by providers that want to be added to the list. Providers who petition by October 15, 2016 will be considered for addition.
Notices To Those Enrolled In Both Medicare And APTC
On September 1, 2016, CMS announced that it is sending out notices to a small number of individuals who are enrolled both in Medicare and marketplace advance premium tax credits (APTC). Medicare Part A (including Medicare Part A benefits received through a Medicare Advantage plan) is minimum essential coverage. Thus an individual enrolled in Medicare Part A is not eligible for APTC or cost sharing reduction payments. An individual enrolled in Medicare and receiving APTC will have to pay the APTC back through the reconciliation process at tax filing time.
Individuals who receive this notice and are enrolled in both marketplace coverage with APTC and premium-free Medicare Parts A and B should terminate their APTC. Although individuals enrolled in Medicare are not prohibited from enrolling in marketplace plans, in most instances marketplace coverage would duplicate and be secondary to Medicare coverage. It would thus not make sense for the individual to continue to pay for marketplace coverage without premium assistance.
If an individual is enrolled in both Medicare Part A and in a marketplace plan, but not in Part B, the individual should enroll in Part B and drop the marketplace plan if he or she is able to do so. This would be the case if the individual has turned 65 in the preceding three months. An individual enrolling in Part B under these circumstances should give the marketplace 15 days of notice prior the beginning of Medicare Part B coverage so that the marketplace can terminate its coverage the day before Part B coverage begins.
If more than three months has elapsed since the individual turned 65, he or she will need to wait until the next open enrollment period (January through March) to enroll in Medicare (and pay a penalty), and may be well-advised to keep the marketplace coverage in the interim. Medicare Part B coverage will begin on July 1 of the year of application, and the enrollee should give the marketplace at least 15 days before Medicare coverage begins to terminate the marketplace plan.
If a person is not eligible for premium-free Medicare Part A and is either enrolled in Medicare Part A or a Medicare Advantage plan and paying a premium for Part A services, that individual should compare the benefits of Medicare (or Medicare Advantage) coverage and marketplace coverage and should keep the more advantageous coverage and terminate the other. Individuals who are not eligible for premium-free Medicare Part A are eligible for advance premium tax credits for marketplace coverage if they terminate Medicare coverage, but individuals who have actually enrolled in Medicare coverage may need to pay the advance premium tax credits they received back for the time they were enrolled in both Medicare and the marketplace with APTC.
from Health Affairs BlogHealth Affairs Blog http://ift.tt/2bInGI2
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