Monday, October 3, 2016

ACA Round-Up: Discontinued Plans, Quality And Network Breadth Info, And More

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On September 30, 2016, the Centers for Medicare and Medicaid Services (CMS) released at its REGTAP.info website (registration required) a description of its strategy for communicating during the 2017 open enrollment period with consumers enrolled in plans that are being discontinued and will not be available for the upcoming year. In October, prior to open enrollment, consumers will receive an official Marketplace Open Enrollment Notice from CMS and a notice from their insurer that their insurance is being discontinued. They will also receive an additional two to three touches acknowledging that their plan is being discontinued, encouraging them the shop for a plan that meets their needs and budget, and assuring them that financial help remains available through the marketplace.

Between November 1 and 15, following the beginning of open enrollment, consumers in discontinued plans will receive a minimum of seven touches informing them that the marketplace will match them with an alternate plan later in the month to ensure that they do not have a gap in coverage if they do not actively enroll in a plan. If consumers login to HealthCare.gov they will see their current and suggested alternate plan listed.

Between November 16 and 21 consumers in plans being discontinued will receive three or more communications informing them that the marketplace has matched them with an alternate plan and that they will receive a welcome kit and bill from this alternate plan in the coming weeks, but that they have no obligation to start their coverage with this plan, and that they should actively shop for coverage by December 15.

Between November 21 and December 15, consumers in discontinued plans who have not actively shopped will receive as many as 20 touches encouraging them to actively renew coverage. The marketplace will send enrollment transactions for these consumers for alternate plans the week of November 21. Between December 16 and 31 consumers in discontinued plans will receive at least five more touches reminding them that they have been matched with alternate coverage. Consumers must still, however, pay their first bill with the new company that they have been matched with or they will not have coverage on January 1. They will not in fact be automatically enrolled in the new plan.

Consumers are under no obligation to pay the alternate company, and may in fact attest to their loss of coverage on December 31 and still get coverage beginning on January 1. Consumers waiting to enroll, however, may not receive their insurance card in a timely basis and may not be able to use their benefits for all of January.

Pilot Testing Of The Use Of Quality And Network Breadth Information

On September 30, CMS issued two brief bulletins updating progress on marketplace pilot test projects. First, it updated a bulletin it had originally released on April 29 reporting on the pilot testing of the qualified health plan (QHP) quality rating system (QRS) for the 2017 open enrollment period. The QRS will be piloted in only two federally facilitated marketplace states, Virginia and Wisconsin, rather than in five states as earlier announced. Several state-based marketplaces will also be displaying QHP quality information. Quality ratings data will become available in the two pilot test states “at some point during open enrollment.”

CMS hopes that information and feedback from the pilot test will provide further information about consumer access to and use of QRS ratings to inform future development of the star rating system. CMS will also use what it learns through the pilot test to develop technical assistance and education materials to help assisters, navigators, agents, brokers, and consumer groups assist consumers with using the star quality ratings once they become more widely available.

The second bulletin reported on the pilot testing of the CMS QHP network breadth rating project. The 2017 HHS Notice of Benefit and Payment Parameters committed CMS to providing additional information on the relative network breadth on HealthCare.gov and the 2017 Annual Letter to Issuers provided additional information on the methodology CMS would use for calculating these ratings. The September 30 bulletin states that the ratings will be displayed with respect to the relative breadth of networks for adult primary care providers, pediatricians, and hospitals in Maine, Ohio, Tennessee, and Texas on a county basis. CMS will evaluate the pilot test and consider expanding it to other states and/or provider types in future years.

Innovation By Exchange Insurers

Finally, on September 30, CMS released its first Innovation in the Marketplace Newsletter. CMS has contended that if insurers are to succeed in the health care marketplaces and serve their consumers, they cannot simply carry on business as usual, but rather must innovate. CMS held an initial marketplace innovation forum in June to identify innovative health plans and is holding a second on October 5. CMS also intends to provide monthly newsletters spotlighting innovative insurers.

The September newsletter focuses on Blue Shield of California and describes its accountable care organization HMO plans, innovative wellness programs, and Teladoc program, which provides seven-days-a-week, 24-hours-a-day access to a physician by telephone or secure video for members who cannot see their doctor during the day.



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