The Blue Cross Blue Shield Association, other industry group and NAIC consumer representatives are suggesting that the NAIC create as many as three separate model laws, not just one, for the group and individual health insurance markets.
The NAIC is working on the Group Market Health Insurance Coverage Model Act to address market issues created by implementation of the Patient Protection and Affordable Care Act. The NAIC asked for comments on the scope of the act through its Regulatory Framework Task Force. The task force is deciding whether to produce a combined model that includes both the group and non-group markets, or whether to continue to have separate model acts for the group market and for the non-group market.
The task force requested comments for any model that seeks to incorporate all current PPACA requirements, and all requirements set to take effect in 2014, that apply to comprehensive major medical health insurance coverage.
“A separate group/non-group approach to this project closely reflects the manner in which most state insurance codes are commonly written,” the BCBSA told the NAIC staff and the chair of the task force, Randy Moses of the South Dakota Division of Insurance.
“Also, we suggest that the NAIC consider the merits of doing a separate model for the small group and the large group given the numerous additional requirements that apply to the small group market,” the association stated.
BCBSA was not alone. The trade association representing the larger health insurance industry, AHIP, or America’s Health Insurance Plans, recommended the creation of three separate models, one for each of the small group market, the individual market and the large group market.
AHIP cited the degree of complex set of facts and conditions of the PPACA changes as they apply to to different markets’ coverage, clarity and usability in promoting three separate market models.