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Moody’s pans PPACA timeline changes

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Federal regulators’ efforts to help consumers cope with public exchange enrollment problems could hurt carriers.

Steve Zaharuk, an analyst at Moody’s Investors Service, says the exchange plan timeline changes announced late last week reveal “an unstable and evolving regulatory environment.”

Making changes “well after insurers have had to commit to product and pricing decisions” could make the new plans harder to run and expose carriers to greater risks, Zaharuk says in a new commentary.

The U.S. Department of Health and Human Services said last week it will use existing regulatory authority to force exchange carriers to accept payment for coverage starting Jan. 1 up until Dec. 31.

Originally, HHS was going to require consumers to choose QHPs and pay for coverage by Dec. 15.

HHS is pushing the plan selection, and payment, deadline back to Dec. 23.

State regulators overseeing a state-based exchange also are allowed to push the deadline for coverage starting Jan. 1 back to Jan. 31.

Zaharuk said carriers might not have enough time to put administrative procedures in place to handle those changes.

Even delivering ID cards could be very difficult, Zaharuk says.

Most exchange plans have high deductibles, and that reduces the risk new enrollees will actually qualify to get benefits before the deadline, Zaharuk says.

“However, this provision could lead to considerable financial exposure if the individual is not promptly removed from the list of insureds and if health care providers are not notified if the extended premium deadline is missed,” Zaharuk says. 

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