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3 ways a PPACA lifeboat form is spamming the CEOs

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Officials at the Centers for Medicare & Medicaid Services (CMS) have had their own little problems over the past 18 months with getting Patient Protection and Affordable Care Act (PPACA) systems and data transmissions perfect.

The federal public exchange enrollment system started off trapping users in glitch quicksand

Investigators recently reported that an initial version of a PPACA plan risk-adjustment software package was missing 7,000 diagnostic codes.

But officials at CMS, an arm of the U.S. Department of Health and Human Services (HHS), want the health insurers filing 2014 PPACA medical loss ratio (MLR) reporting forms, and the 2014 PPACA risk corridors program data that’s supposed to go into the MLR reporting forms, to get their submissions right the first time.

The risk corridors program is one of three big PPACA programs that PPACA drafters created in an effort to keep new PPACA health insurance underwriting and product design rules from drowning health insurers. The risk corridors program is supposed to use cash from health insurers that have good underwriting results in 2014, 2015 and 2016 to help health insurers that have bad results in those years.

The investigators who drew attention to the missing diagnostic codes noted that some insurers have complained about having trouble getting help from CMS with understanding how to comply with the risk corridors program reporting rules. Insurers won’t get key data they need to fill out the risk corridors form until June 30, and they are supposed to file the data by July 31.

CMS wants insurance company chief executive officers (CEOs) and chief financial officers (CFOs) to attest to the accuracy of the MLR and risk corridors program being submitted.

To ensure that insurers submit perfect risk corridors program data, CMS has set up the reporting form in such a way that, when errors occur, the system sends both error messages and warnings to the workers submitting the data.

The system also encourages active communication between the workers submitting the data and the workers’ CEOs and CFOs by sending warning messages to the CEOs and CFOs. The warning messages to the C-suite executives tell them that they can attest to the data submissions if the warning messages appear to be unfounded.

CMS officials describe system validations for the 2014 reporting year in a technical memo aimed at users.

For a look at a few of the many reasons CMS could encourage CEOs to call the workers submitting the data into their offices for cordial chats, read on.

 Angry cat

1. Blank tabs

The Health Insurance Oversight System (HIOS) will alert the data submitter’s CEO and CFO if the submitter has tried to submit any submissions that contain blank reporting form parts.

See also: Bad MLR forms to trigger CEO emails

Puzzled dog

2. Unusual premium per life year

HIOS will inform the CEO if the filing worker submits a form showing that the direct written premium for a year appears to be less than $120 or more than $12,000.

See also: CMS rules on exchange plan servers 

Angry dog

3. Missing risk corridors template

A data filing worker could end up talking to the CEO if the company has at least one qualified health plan (QHP) and the company has not filed risk corridors plan-level templates for all of its issuers that offered exchange-certified QHPs in 2014.

See also: S&P sees PPACA risk corridors program funding gap