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Agencies Seek PPACA Implementation Comments (With Federal Register Links!)

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Federal regulators are asking members of the public for comments on how the government should implement the Patient Protection and Affordable Care Act medical loss ratio and premium review provisions.

The Internal Revenue Service, the Employee Benefits Security Administration and the Centers for Medicare and Medicaid Services will join Wednesday to publish a request for comments on the PPACA minimum medical loss ratio provisions in the Federal Register.


A copy of the PPACA minimum MLR request for comments is now available here.

A copy of the PPACA rate review request for comments is now available here.


CMS will published another request for comments Wednesday on the PPACA premium review process provisions, according to the Office of the Federal Register.

Comments are due May 14.

The IRS, EBSA and CMS say they are especially interested in comments from commenters with actual experience with minimum medical loss ratio standards, ideas about definitions and calculation methods, and ideas about whether and how insurer data should be “aggregated,” or combined, at the policy, group, plan type, line-of-business, carrier and state levels.

“What are the pros and cons associated with using various possible level(s) of aggregation for different contexts relating to implementation of the provisions in Section 2718 (that is, submitting medical loss ratio-related statistics to the secretary, publicly reporting this information, determining if rebates are owed, and paying out rebates)?” the agencies ask, according to a preliminary version of the request for comments provided by the OFR.

The agencies also will ask for comments on data reporting and submission methods, rebates to customers who have paid too much for coverage, enforcement methods, federal income tax considerations, and strategies for reducing paperwork burdens.

In the request for comments on the PPACA rate review provisions, CMS officials will ask for commenters’ views on existing state rate review processes, existing methods for calculating medical trends, and data aggregation rules.

CMS also will ask about how states define “unreasonable rate increases,” rules for public disclosure of rate increase information, ideas about how to go about excluding plans that impose “unreasonable rate increases” from the new state health insurance exchange system, and ideas about how to minimize the rate review process paperwork burden.



Our Guide To A New Health Reform World is available here.

Coverage of the key PPACA provisions is available here.


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