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Federal health rate reviewer talks to SOA

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One of the officials who helps the Center for Consumer Information and Insurance Oversight (CCIIO) run the health insurance rate review program gave actuaries a peek into his world by appearing on a recent Society of Actuaries (SOA) podcast.

Dave Dillon, an actuary who belongs to the SOA, interviewed Brent Plemons, a health insurance specialist in the CCIIO rate review division. 

The Patient Protection and Affordable Care Act (PPACA) now requires filings for all non-grandfathered individual and small-group major medical products to go through a rate review process. Reviewers are supposed to verify whether filings comply with PPACA requirements, and whether proposals for rate increases of 10 percent or higher appear to be reasonable.

See also: CMS posts 2017 PPACA World rules

CCIIO, which is a unit of the Centers for Medicare & Medicaid Services (CMS), oversees rate reviews in all states and conducts the reviews itself for five states. CMS is an arm of the U.S. Department of Health and Human Services.

When CCIIO handles the rate reviews, outside consultants do the actuarial heavy lifting, then send their work to the CMS Office of the Actuary, Plemons said. Once the CMS actuaries go over the consultants’ work, they send the results to the CCIIO rate review team. The rate review team makes the official determination about whether a big increase proposal appears to be reasonable. CCIIO posts summary information for all rate increase requests on the Web.

Last year, CCIIO held weekly conference calls for the rate reviewers in states that handle their own rate reviews, Plemons said. He said CCIIO will bring back the weekly conference calls this year.

States that conduct their own rate reviews have to get product information and initial rate information into their systems by May 11, but they can let final rates come in as late as July 15, according to Plemons.

CCIIO did determine that some 2015 rate increase proposals were unreasonable. But that was probably mainly due to issuer uncertainty about the rate review process, Plemons said. The CCIIO rate review division specialist also said he could not remember any cases of 2016 rate increase proposals being found to be unreasonable.

CCIIO did work with issuers to address 2016 rate proposal concerns, Plemons said.

See also: Gloom, hope shape early 2016 health rate filings

One problem that cropped up last year was issuer efforts to, for example, use rates or cost-sharing provisions to pass different rate increases on to bronze-level enrollees and platinum-level enrollees in the same plan, Plemons said.

CCIIO does not let an issuer impose different increases on enrollees in different metal-level versions of the same plan, Plemons said.

In other cases, he said, some issuers tried to redesign their product offerings by canceling all existing products and replacing them with new products. ”Don’t terminate all of your products,” Plemons said.

Even though an issuer may simply be trying to replace its products, CCIIO sees the termination of all of an issuer’s products as a market withdrawal, and CCIIO rules forbid an issuer that withdraws from a market from returning for five years, Plemons said.

Plemons said another concern is how some issuers applied a CCIIO rule that lets an issuer redact trade secrets from the version of the rate proposal that’s posted on the Web.

Some issuers redacted too much information, Plemons said. ”Your issuer name is not redactable,” Plemons joked.

This year, if an issuer redacts too much information, CCIIO will ask the issuer to replace the over-redacted version of the rate filing with a more complete filing, Plemons said.

See also:

Feds offer states $40 million in PPACA cash

SERFF rising up to take on health care exchange activities

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