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The U.S. Department of the Health and Human Services (HHS) is still propping the door open for the 2015 open enrollment period at the public exchanges it runs, but it’s already posted applications for insurers that want to sell coverage through HHS exchanges in 2016.

The Center for Consumer Information & Insurance Oversight (CCIIO), the HHS division in charge of the exchange program, has posted the 2016 qualified health plan (QHP) application packet along with a variety of QHP application instructions and templates.

Major QHP application areas cover topics such as whether a would-be QHP issuer is properly licensed, whether it’s in good standing with state insurance regulators, whether it has accreditation from major health plan quality organizations, and whether its provide network has enough of the right kinds of health care providers in the right places.

Other areas deal with matters such as whether a QHP offers the Patient Protection and Affordable Care Act (PPACA) essential health benefits or acceptable substitute benefits; what drugs a QHP covers; and whether a QHP has benefits that regulators view as discriminatory.

One appendix provides a helpful guide to the abbreviations and acronyms used in the application, such as AVC (actuarial value calculator) and SADP (stand-alone dental plan).

The HHS exchanges attracted multiple issuers throughout most of the country for 2014, and again for 2015, but insurers had no PPACA coverage experience when they applied for 2014 and 2015 HHS exchange slots. Some insurers have seemed to be happy with their exchange operations, but none has posted detailed exchange QHP performance data, and one new plan that depended heavily on exchange business has already failed.

Another challenge may be that, although potential 2016 exchange QHP issuers now have data on claims at PPACA exchange QHPs and other PPACA-compliant major medical insurance plans, they may get to the 2016 exchange QHP application deadline without knowing how three major PPACA risk management programs — a reinsurance program, a risk-adjustment program and a risk corridors program — will really work.


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