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Insurance Exchanges-Bonnie Washington

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The National Health Council held A Briefing on Essential Health Benefits on August 3, 2011. This slide show was the luncheon presentation explaining state health exchanges.

The National Health Council held A Briefing on Essential Health Benefits on August 3, 2011. This slide show was the luncheon presentation explaining state health exchanges.

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  • HHS issued two notices of proposed rulemaking on July 11, 2011. Comments are due for both rules on September 28, 2011:Establishment of Exchanges and Qualified Health Plans Standards Related to Reinsurance, Risk Corridors and Risk AdjustmentHHS must determine whether a state will operate an exchange by January 1, 2013The rule gives states additional flexibility to meet this deadline by granting “conditional approval” to states that likely will be ready for implementation by 2014, but cannot yet be certified as ready on January 1, 2013In order to receive approval from HHS, the state must submit a detailed exchange plan and demonstrate operational readiness
  • WV – plan rep elected by majority vote among 10 top plans by enrollment
  • Transcript

    • 1. Insurance Exchanges /Federal Regulations & State Flexibility
      August 3, 2011
      Bonnie Washington
      Avalere Health LLC
    • 2. States Have Substantial Implementation Responsibilities in the Next 3 Years
      Federal Activities
      Deadline for Approval or Conditional Approval of State Exchange Plan
      January 1, 2013
      Proposed Exchange Rule Released
      July 2011
      Final Exchange Rule Expected
      Late 2011
      Affordable Care Act Passed
      March 23, 2010
      Exchanges Begin
      2014
      2010 2011 2012 2013 2014
      State Activities
      Pursue Legislation or Executive Order to Implement an Exchange
      File Exchange Plan
      Establish Governing Boards
      Operational Planning & Implementation
      Open Enrollment
      Plan Bids Submitted
    • 3. States Are Busy Implementing Exchanges As the Federal Government Issues Regulations
      WA
      ME
      MT
      ND
      VT
      NH
      MN
      OR
      MA
      WI
      NY
      ID
      RI
      SD
      CT
      MI
      WY
      PA
      NJ
      IA
      NE
      DE
      OH
      NV
      IN
      IL
      MD
      WV
      UT
      VA
      D.C.
      CA
      CO
      MO
      KY
      KS
      NC
      TN
      OK
      SC
      AZ
      AR
      Adopted Establishing Legislation (11)
      NM
      GA
      AL
      MS
      Exchange in Operation (2)
      LA
      TX
      AK
      Adopted Legislation Requiring New Study (3)
      FL
      Issued Executive Order Requiring New Study (6)
      HI
      In Progress (28)
      Source: Avalere Health Reform State Insights, July 15, 2011.
    • 4. Proposed Exchange Regulation Grants States Significant Flexibility to Establish Exchanges
    • 5. Governance Structure and Composition
      Federal Requirements
      • Exchange governing bodies may be housed within government agencies or as freestanding non-profit entities (or a combination of both)
      • 6. At least half of all voting board members must represent consumer interests
      10-person board in the Department of the Insurance Commissioner
      Includes consumer and employer representation, plus one plan rep
      WV
      WV
      CA
      Government-Run
      Independent
      5-person independent, quasi-governmental board
      Includes appointed members that may not represent health plans or providers
    • 7. WA
      ME
      MT
      ND
      VT
      NH
      MN
      OR
      MA
      WI
      NY
      ID
      RI
      SD
      CT
      MI
      WY
      PA
      NJ
      IA
      NE
      DE
      OH
      NV
      IN
      IL
      MD
      WV
      UT
      VA
      D.C.
      CA
      CO
      MO
      KY
      KS
      NC
      TN
      OK
      SC
      AZ
      AR
      NM
      GA
      AL
      MS
      LA
      TX
      AK
      FL
      HI
      Presence of Benefit Mandates Varies Significantly By State
      Number of Mandates
      < 15
      16 - 30
      31 - 45
      46 – 60
      > 60
      1.Source: Council for Affordable Health insurance, http://www.cahi.org/cahi_contents/resources/pdf/MandatesintheStates2010.pdf
    • 8. Health Plan Bidding Process
      Federal Requirements
      • Give exchanges discretion on plan contracting, including accepting any qualified plan, conducting competitive bidding, or conducting case-by-case negotiations
      • 9. States may set additional requirements for participating plans
      UT
      The state’s exchange accepts all health plans licensed to offer coverage in the state
      WV
      Passive Facilitator
      Active Purchaser
      Requires plans to adhere to specific benefit designs, excluding those that do not compare favorably
      MA
    • 10. Small Business Health Options Program (SHOP)
      Federal Requirements
      • States integrate SHOP with individual exchange or administer them separately
      • 11. Includes groups up to 100 employees—states may include larger employers or limit to <50
      • 12. Exchanges must offer employee choice—states and employers may limit plan options or offer extra flexibility to choose between tiers
      Separate exchanges; SHOP limited to groups <50
      Minimum requirements for employee choice
      WV
      Limited Market, Less Flexibility
      Large Market, Broad Flexibility
      Integrated exchanges; SHOP eligibility expanded to large groups
      Broad employee choice options for employers
    • 13. Other State Flexibility in Exchange Implementation
      *Employee choice means that employers select a benefit tier (e.g., silver) and employees can enroll in any plan in the tier (e.g., Aetna or Blue Cross Blue Shield)
    • 14. Separate Rulemaking Will Address Additional Exchange Related Topics
      Detailed requirements on the federal fall-back exchange that will operate in states that fail to establish an exchange will likely be covered in subregulatory guidance

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