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SERFF rising up to take on health care exchange activities

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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.

HHS is getting ready to pump three major PPACA regulation proposals into the Federal Register.

HHS published a 131-page proposed rule implementing PPACA health insurance market and rate review rules and a 119-page proposed rule implementing the PPACA essential health benefits (EHB), actuarial value and accreditation provisions.

On the same day, HHS joined with the U.S. Treasury Department and the U.S. Labor Department to publish an 81-page proposed rule implementing PPACA group health plan wellness program provisions.

HHS also is publishing other, related documents. For example, HHS will be publishing a brief notice stating that it is going ahead with previously announced plans to put the National Committee for Quality Assurance and URAC in charge of accrediting the QHPs that will be eligible to participate in the PPACA health insurance exchange program.

While processes supporting licensure and solvency will not exist in SERFF, the ability to ensure an issuer is licensed and solvent in relation to the QHP certification will be, the Health Insurance Exchange Blueprint document stated.

The Blueprint Responses is a document created to assist states with their exchange application, but suggested that states should consult their CCIIO state officer for specific questions regarding their exchange blueprint, according to the memo on the document posted by the NAIC and its Center for Insurance Policy and Research.

The NAIC is hoping that states will integrate the exchange system with SERFF’s Plan Management functionality. SERFF intends to provide a Web service that will send data from SERFF to the state’s exchange and vice versa.

SERFF also intends to provide technical support related to SERFF plan management functionality by providing a user manual, end-user training, online help tutorials, and ongoing technical support via a help desk.

SERFF also intends to provide functionality related to periodic recertification of insurers, yearly renewal of QHPs, revocation of an issuer or QHP certification, and assessing and implementing revisions to QHPs already available on the Exchange. SERFF will not provide functionality related to decertification, but will have the ability to track the occurrences as needed, the document states.


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