Final letter to Issuers on Federally Facilitated and State Partnership Exchanges
April 17, 2013
On April 5, 2013, the Department of Health and Human Services released its final Letter to Issuers on Federally Facilitated and State Partnership Exchanges. This letter lays down guidelines for insurers that will sell qualified health plans on the federal exchanges in 2014.
We have not yet had time to do a thorough review but think that Timothy Jost’s review in Health Affairs will give you an excellent overview.
Overview of the final letter The topics covered by the issuer letter are virtually identical to those covered by the proposed letter. Its chapters include certification standards for qualified health plans, QHP certification processes, QHP performance and oversight, stand-alone dental plans, consumer enrollment and premium payment, consumer support, and tribal regulations and support. Not only are all of the main headings of the paper identical to the proposed letter, all of the subheadings are identical as well. This does not mean, however, that nothing has changed; one just has to dig deeper.
CMS begins by again reaffirming its intention to rely to the extent possible on states in overseeing the 2014 market reforms and on state partnership exchanges to assess QHP compliance with certification standards in its own certification of compliance. For example, CMS will rely primarily on the states to assess the network adequacy of QHPs. Where states lack the authority or means to regulate network adequacy, CMS will rely on an issuer’s accreditation status for demonstrating adequacy. Unaccredited issuers must submit an access plan and CMS will monitor compliance, for example through complaints. (On April 5 CMS also published a chart setting out who is responsible for determining network adequacy.) Continue reading on the Health Affairs website.