The Center for Consumer Information & Insurance Oversight (CCIIO) is updating the standard federal notices that issuers of individual coverage are supposed to use to tell enrollees that exchange plans are dead.
CCIIO, an arm of the Centers for Medicare & Medicaid Services (CMS), is also updating the notices issuers under its direct oversight are supposed to use when they renew enrollees’ coverage.
CCIIO posted the notice update drafts Thursday on its section of the CMS website. Comments on the drafts are due June 27.
In the new drafts, CCIIO is revising standards it set in a coverage notice bulletin it issued in 2014.
The Patient Protection and Affordable Care Act of 2010 (PPACA) requires all group and individual health coverage issuers to send coverage renewal, non-renewal or termination notices that meet standards specified by the secretary of the U.S. Department of Health and Human Services (HHS). CMS is part of HHS.
States that enforce the PPACA guaranteed renewability requirement can set their own coverage change and renewal notice standards. The standards CCIIO is proposing would apply directly only in states in which HHS enforces the standards.
HHS is directly in charge of enforcing the guaranteed renewability standards only in Missouri, Oklahoma, Texas and Wyoming. But other states may choose to base their own coverage notice standards on the HHS standards.
The PPACA guaranteed-renewability standards apply in the off-exchange market as well as the exchange market.
The new draft includes attachments showing what notices would look like in six different scenarios. In one scenario, for example, the issuer is sending a discontinuation notice for the off-exchange individual market and automatically enrolling the individual in a replacement plan.
In another scenario, the issuer is sending a discontinuation notice to a PPACA public exchange qualified health plan enrollee who is not being enrolled in an off-exchange plan.
An issuer that’s discontinuing an exchange QHP may be able to shift the enrollee to an alternative exchange QHP automatically, but an issuer may not automatically shift an enrollee in an exchange QHP that’s being shut down into an off-exchange plan, officials say in a discussion of the PPACA guaranteed renewability requirements.
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