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June 11, 2012 at 09:23 AM
Interest groups are trying to get their ideas into a document that could affect how state insurance regulators implement the Patient Protection and Affordable Care Act of 2010 (PPACA).
The groups are commenting on a draft of a form review white paper now being developed by a team at the Exchanges Subgroup at the National Association of Insurance Commissioners (NAIC), Kansas City, Mo.
The list of commenters include groups that often comment on Exchanges Subgroup proceedings, such as America’s Health Insurance Plans (AHIP), Washington, and the Blue Cross and Blue Shield Association, Chicago.
The list also includes groups that are less involved with the NAIC, such as the Leadership Conference on Civil and Human Rights, Washington, and a coalition of groups with an interest in reproductive law.
The form review team says in the draft that it is developing the paper to help state policymakers implement PPACA provisions that affect certification of “qualified health plans” and reviews of the QHPs’ enrollment forms and other forms.
PPACA calls for states to set up a new system of health insurance exchanges, or Web-based health insurance supermarkets. The QHPs would be the plans that could sell coverage through the exchanges.
Individuals and small groups could use new federal health insurance tax subsidies to buy coverage through the exchanges. Other individuals also could buy coverage through the exchange system.
Candy Gallaher, a senior vice president at AHIP, emphasizes process efficiency in the AHIP comment.
White paper drafters talk about using the existing state form review system – the System for Electronic Rate and Form Filing (SERFF) — to handle the QHP form reviews.
That might be a good approach, but regulators ought to look at how the changes would work in practice and whether a state really can implement the required changes through SERFF, Gallaher says.
Gallaher says she is glad to see white paper drafters acknowledging that PPACA will lead to “an intense period of increased number of filings and new changes.”
“Your recommendations for tools to streamline the process, including training for industry filers and state form review and actuarial staff is very prudent,” Gallher says.
Joan Gardner, a state services specialist at the Blue Cross and Blue Shield Association, says she worries about the white paper giving regulators the impression that some PPACA rules that apply only to QHPs sold through a PPACA exchange also apply to other plans.
