June 21, 2017, was the last day for insurers to file qualified health plan applications in the 39 states that use HealthCare.gov, including federally facilitated marketplace (FFM), plan management, and state-based marketplace-federal platform states. There were reportedly a few additional defections, including Anthem from Wisconsin and Indiana, but most insurers are back from last year, and a there are a few new entrants, notably Centene in several states.
According to slides posted at the CMS REGTAP.info website, insurers may make any changes they wish to their plan filings until August 16, 2017, except for adding plans, changing plan type or child-only value, or changing service areas without permission from CMS, as long as they get state regulator approval. Insurers that wish to change the service area served by a plan must petition CMS by August 4, 2017.
From August 17, 2017, CMS will not allow further changes except data corrections needed to correct data display errors and align QHP plan displays with products and plans approved by the states. Insurers will have a final opportunity to withdraw plans during the plan confirmation process, which takes place between September 12 and 15, 2017.
These deadlines are not statutory but are rather established by guidance. It is hard to believe, therefore, that if an insurer steps forward to cover a bare county (or which 44 currently are believed to exist in Missouri, Ohio, and Washington, CMS would not accept a late filing.
The QHP filings are not public information. Some of the data contained in the applications will be made available in public use or landscape files in the fall. QHP filings contain some information on proposed rates, but uniform rate review templates for individual and small group market rate filings are not due at CMS until July 17, 2017 (although states have earlier deadlines, many of which have passed). Proposed rates will be published on the CMS website and by states on August 1, 2017. Final rates must be published by November 1, 2017.
Court Orders House And Administration To Respond To States’ Request To Intervene In House v. Price
On June 22nd, the District of Columbia Court of Appeals today ordered the government and the House to respond to the motion to intervene in House v. Price filed by attorneys general from 17 states and the District of Columbia. The House and administration must respond in 10 days, and the states have 7 days to reply.
The states asked to intervene in the appeal of the litigation, arguing that uncertainty caused by the litigation was threatening their health insurance markets and that their interests were not adequately represented in the litigation. The House and the administration then asked the court not to lift the stay that has been imposed on the litigation to hear the states’ request, but the court ruled in favor of lifting the stay to let the states present their case for intervention.
Pre-Enrollment Verification For Special Enrollment Periods
On June 23, 2017, HealthCare.gov began requiring pre-enrollment verification for eligibility for loss of minimum essential coverage and permanent move special enrollment periods (SEPs). CMS has posted at the Center for Consumer Information and Insurance Oversight website examples of the forms that it intends to use to:
- remind people who qualify for a SEP to pick a plan and confirm their eligibility,
- inform applicants who have already applied and picked a plan that they have 30 days to document eligibility,
- warn applicants ten days before the application of the 30-day period who have picked a plan but have not yet submitted eligibility verification documentation to do so,
- notify applicants when the documentation they have submitted is insufficient and to inform them of what more is needed to verify eligibility (apparently within the original 30-day period),
- notify applicants that their SEP eligibility has been verified and that they will be enrolled in coverage once they pay their first month’s premium (or, if they have not yet selected a plan, once they select a plan and pay the binder premium.) (The notice, starts out “Good news, . . .” suggesting that CMS still sees some benefit in ACA coverage), or
- notify applicants that the 30-day period for verifying SEP eligibility has expired. This may mean that applicants lose SEP eligibility, but some applicants may still have time remaining in their SEP eligibility period to start the process over again.
CMS also released on June 23, 2017, at its REGTAP.info website: a very useful chart listing available SEP categories; the regulatory authority for availability of each SEP through the exchanges; whether an SEP is available through the federally facilitated exchange (FFE), state-based exchanges (SBE), or outside of the exchanges; and requirements for pre-enrollment verification.
The six broad categories of SEPs listed are:
- loss of qualifying health coverage;
- change in household size (for example, through birth or marriage);
- change in primary place of living;
- change in eligibility for exchange coverage or for help paying for coverage;
- enrollment or plan error; and
- other qualifying circumstances (such as domestic abuse or spousal abandonment or exceptional circumstances).
Most categories are broken down into several subcategories. For example, “change in eligibility” is broken down into four categories: becoming newly eligible for exchange coverage because of a change in citizenship or residency status or leaving incarceration; becoming newly eligible or ineligible for premium tax credits or changed eligibility for cost-sharing reductions; having been previously in the Medicaid coverage gap in a non-expansion state and becoming newly eligible for premium tax credits; or gaining or maintaining Native American status.
Most SEPs are available in the FFE, SBEs, and off-exchange, but those that relate to exchange or tax credit eligibility are in most instances available only on-exchange, and at least one SEP—for consumers who lose dependents or who cease to be dependents—is available in some SBEs and in some states off-exchange but not through the FEE. Several of the SEPs are only available for consumers who had coverage before they became eligible.
from Health Affairs BlogHealth Affairs Blog http://ift.tt/2u2dWNk
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