The NAIC is planning to have a big role in states’ ability to adequately perform plan management activities related to health insurance exchanges.
The NAIC wants to support both exchanges that are state-based and state partnership exchanges created under the health care reform law, by giving them the capacity to handle the technology infrastructure needs that will come with plan management, according to a blueprint the NAIC has posted online for interested parties.
The System for Electronic Rate and Form Filing or SERFF, is working from the “Blueprint for Approval of Affordable State-based and State Partnership Insurance Exchanges,” a document provided by the Centers for Medicare & Medicaid Services (CMS), an arm of the U.S. Department of Health and Human Services (HHS).
If the Patient Protection and Affordable Care Act (PPACA) takes effect on schedule and works as drafters expect, it will give individuals and small groups the ability to buy standardized coverage from qualified health plans (QHPs) through the new exchanges, or Web-based insurance supermarkets, by late 2013, with the coverage to start taking effect in 2014.
The NAIC’s SERFF system, which works in partnership with the industry to automate the rate and form filing process, plans to assist the exchange requirement in the areas of plan management technology and privacy and security.
For example, states may use SERFF to collect insurer exchange applications. The standards currently supported by existing or future SERFF functionality in areas like network adequacy and accreditation and quality, according to a Blueprint Response document from NAIC and SERFF.
SERFF has taken steps to ensure the application has the capacity to support the volume of activity that will come with the SERFF plan management functionality, according to the document.
For items relevant to SERFF plan management, the NAIC is working with the CMS to ensure the application complies with all technology standards.
SERFF is also working in collaboration with HHS’s Center for Consumer Information and Insurance Oversight (CCIIO) on quality assurance tools including load testing and beta testing to ensure the SERFF meets the business needs of the state.
“The big issue, in my mind, is that we are hearing conflicting things about whether the Feds and the states will be able to start operating exchanges on January 1, 2014, said one D.C.-based health care lobbyist.
“There is a big difference between churning out hundreds or thousands of pages of bureaucratese in proposed rules and producing information technology/operating systems to perform all of the complex tasks done through, in, or by exchanges – determining eligibility for programs – i.e., Medicaid, CHIP, etc.; checking income levels, including review of IRS types of information; providing subsidies for those who are eligible for subsidies; qualifying and certifying qualified health plans offered for sale on exchanges; getting those products available; making sure the system works for that a particular customer can look at available products, pick a product, enroll, etc., and probably much, much more,” the lobbyist said.