The managers of the federal health insurance supermarket seem to have decided to try to be polite to the insurers that brave uncertainty to put plans on its shelves.
The Centers for Medicare & Medicaid Services (CMS) has come out with a list of 2015 exchange plan compliance review priorities that’s almost the same as the list of priorities CMS issued for 2014.
The compliance priority list shows what CMS officials will look for when review the insurers issuing qualified health plans (QHP) through the public exchanges that CMS runs for the U.S. Department of Health and Human Services (HHS).
Officials emphasize that the list does not put any limits on the authority of CMS to decide what to review.
“The compliance review that is the subject of this document is separate from other audits and reviews that may be conducted to assure compliance” with PPACA, officials say.
Officials say QHP issuers could also face the following types of compliance efforts:
PPACA minimum medical loss ratio (MLR) compliance audits.
Policy and rate filing reviews.
Audits of plans eligible for PPACA reinsurance program payments.
But CMS officials have a reason to be as welcoming to health insurers as they can be, under the circumstances: CMS is waiting to see what QHPs insurers want to offer through the HealthCare.gov system in 2016. Applications for 2016 HealthCare.gov slots are due May 15.
Dental plan issuers expressed strong interest in selling stand-alone dental plans (SADPs) through HealthCare.gov through a voluntary notice program, but HHS collected the SADP notices before oral arguments in the King vs. Burwell U.S. Supreme Court case drew attention to the possibility that HHS may lose the ability to offer PPACA premium subsidies in the state that use the HealthCare.gov enrollment system.
For a look at how some of the returning compliance priorities look the second time around, and at a new set of compliance priorities, read on.
1. Enrollment and termination management
In 2015, a QHP issuer is supposed to adhere to some requirements that were already in effect in 2014 but, at that point, may not have been realistic.
A QHP issuer is supposed to allow for enrollment through the exchange, not just through direct enrollment.
A QHP issuer is also supposed to reconcile enrollment files with the exchange at least once a month, send coverage termination notices to affected enrollees promptly, and maintain coverage termination notices in accord with exchange standards.
It’s not clear from public HHS documents how well HealthCare.gov QHP issuers could have met those standards in 2014, or can use automated HHS exchange systems to meet those standards this year.