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PPACA: Texas Explains Filing Procedures

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Lone Star state officials have put out a bulletin to help health insurers and health maintenance organizations bring policy and contract forms into compliance with the Patient Protection and Affordable Care Act (PPACA).

PPACA, part of the new federal Affordable Care Act package, will require health care carriers to make many changes in the coverage rules by Sept. 23.

Health insurers should use the “file and use” rules for policy form amendments to update their policies, Texas department officials say in the new PPACA Implementation, Form Filings bulletin.

Insurers can combine amendments and riders for plans that will qualify for “grandfathered status” under PPACA and plans that will bear the full brunt of PPACA changes in the same filing, officials say.

Texas does not have a “file and use” program for HMO filings, but the Texas department will review amendatory contract language accompanied by a completed PPACA Uniform Compliance Summary and related forms will be reviewed as soon as possible, officials say.

Like health insurers, HMOs can combine grandfathered and non-grandfathered amendments and riders in the same filing, officials say.

Insurers and HMOs also can use the standard filing process, but reviews of standard filings will not be expedited, officials say.

“Due to the expected volume of filings, the department requests that health benefit plan issuers to limit form filings to conforming amendments for PPACA purposes, utilizing the PPACA Uniform Compliance Summary,” officials say. “The department is dedicating its resources to PPACA filings and will review such filings as soon as possible. As a courtesy, please consider the department’s efforts before filing non-PPACA-related forms.”