The Michigan Office of Financial and Insurance Regulation (OFIR) is starting to apply new health insurance rate filing rules today in an effort to comply with the rate review provisions of the Patient Protection and Affordable Care Act of 2010.
Michigan has been requiring all carriers to file individual health rates, but only Blue Cross Blue Shield of Michigan and health maintenance organizations have had to file large group and small group rates, Allen says.
Starting today, commercial carriers will have to file small group rates as well as individual rates, Amy Allen, a deputy commissioner at the OFIR health plans division, says in a rate review memorandum.
Carriers must file the rates through the System for Electronic Rate and Form Filing (SERFF) system, and they must fill out a new Rate Summary Worksheet for each individual and small group filing.
To implement the rate review provisions in PPACA, the U.S. Department of Health and Human Services (HHS) is requiring states to post carriers’ explanations for any proposed individual or small group rate increases that exceed 10% on the Web.
States also must provide a mechanism that members of the public can use to comment on the increase proposals posted on the Web, Allen says.
A state must forward the double-digit rate increase proposals to the federal Centers for Medicare & Medicaid Services (CMS) through a new Health Insurance Oversight System (HIOS).
“If you have not yet registered with HIOS or taken the training webinars, we strongly encourage you to do so immediately,” Allen says.
In a collection of answers to frequently asked rate review questions, Michigan OFIR officials note that the new rate review process does not apply to existing health coverage rates, disability insurance rates or health maintenance organization rates.
Michigan is defining a “small group” as a business with 2 to 50 eligible employees. In 2016, Michigan will change the definition to cover a business with 2 to 100 lives, to conform with the PPACA definition, officials say.