ADEA State Update

Update on Health Insurance Marketplaces with Less Than 50 Days Left Before October 1

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With less than 50 days left until October 1–the date that open enrollment will begin in the health insurance marketplaces–states, the District of Columbia, and the federal government are all working at a feverish pace to get ready.

Initially, 17 states and the District of Columbia committed to operating a state-based marketplace; seven states committed to operating a state-partnership marketplace; and the federal government committed to operating the marketplace in 26 states. However, as the October deadline approaches, several states have asked the federal government for additional assistance as they scramble to implement the Affordable Care Act (ACA) and develop and test web portals that will run the marketplaces.

In January 2013, Utah and New Mexico were conditionally approved to operate a state-based marketplace. However, Utah has received federal approval to operate a state-based Small Business Health Options Program (SHOP)-only marketplace. Under this agreement Utah will operate the SHOP marketplace and the federal government will operate the individual insurance marketplace. Additionally, the New Mexico Health Insurance Exchange Board recently approved a plan to operate a state-based SHOP-only marketplace. Earlier this year, Mississippi’s request to operate a state-based exchange was denied by the federal government because the application submitted was not properly approved by the governor. However, officials with the Mississippi Insurance Department (MID) have confirmed that MID is working on obtaining approval to operate a state-based SHOP-only marketplace.      

Other states such as Connecticut, Oregon, and Nevada plan to delay implementation of certain features of its web portal, such as a chat function and a feature allowing brokers to track the customers they enroll, as they focus their attention on web portal features with higher impact and higher priority.

The federal government is also facing ACA implementation challenges. On July 2, 2013, the Department of the Treasury (DOT) announced that there will be a delay in implementing the employer mandate and reporting requirements for insurers under the ACA until 2015 to allow time for the government to complete its operational preparedness and give employers time to adjust benefits accordingly. In addition, according to a June 2013 report by the U.S. Government Accountability Office (GAO), the federal government is behind schedule as it races to meet the October 1 deadline. For example, to support consumer-eligibility determinations, the Centers for Medicare and Medicaid Services (CMS) is developing a data hub that will provide electronic, near real-time access to federal data, as well as provide access to state and third party data sources needed to verify consumer-eligibility information. However, the GAO report states that CMS is behind schedule in conducting final testing of the data hub with federal and state partners and is also behind schedule in training consumer assistance guides. Additionally, the U.S. Department of Health and Human Services (HHS), Office of Inspector General (OIG) in an August 2013 report cited concerns regarding delays in the final testing of the data hub, as well as a failure by CMS to remedy security vulnerabilities in the data hub identified during testing.

As ACA deadlines approach, states and the federal government forge ahead. States were required to submit their insurance rates to HHS for final review by July 31. HHS plans to sign contracts with insurers in the federally-facilitated marketplace by September. Other key dates to be aware of: insurance coverage can begin on January 1, 2014, and open enrollment ends on March 31, 2014.

HHS has created a website to educate consumers about the ACA and health insurance marketplaces. HHS has also posted a Q&A section for consumers with specific questions, including questions regarding dental coverage.

Generally, states are addressing pediatric dental coverage in different ways. Wisconsin has posted a guidance document to help consumers more clearly understand their options with regard to dental coverage. Specifically, Wisconsin is requiring all health insurers authorized to write comprehensive individual and small employer group health insurance to provide a notice to insureds indicating whether the policy being offered includes coverage of pediatric dental services.

On June 25, California announced its selection of pediatric dental plans and rates. The plans and rates apply to children up to 19 years old. The products include stand-alone plans, and all can be bundled with health insurance for a single premium. However, the Plan Management and Delivery System Reform Advisory Group met August 6 to further discuss pediatric dental benefits. In a letter dated June 27, the California Insurance Commissioner urged Covered California, California’s health benefit exchange, to embed dental coverage in medical plans. In July, Covered California conducted a survey of insurance plans. According to Covered California staff, eight insurance plans responded indicating that they are willing to develop an embedded product, and two stated they are unwilling to develop an embedded product. Insurance plans also stated that these embedded products could not feasibly be developed until 2015. During its August 6 Advisory Group meeting, staff from Covered California accepted responsibility for a lack of transparency and weaknesses in its communications process during its implementation of pediatric dental benefits and vowed to correct the issue by, in part, re-launching the Pediatric Dental Project. The Pediatric Dental Project will allow Covered California to continue working with stakeholders to architect what it is calling the “right” pediatric dental policy. The Advisory Group plans to develop a new pediatric dental policy and present the policy for a Board vote by December 19. Additionally, the Advisory Group is also discussing the possibility of making pediatric dental coverage mandatory in California.

Several states–including California, Connecticut (sample standard and high option plans), Florida, Maryland, Montana, New York, Ohio, Oregon, Rhode Island, South Dakota, and Vermont–and the District of Columbia (click here for D.C. SHOP rates) have made information related to their premiums publicly available. The breadth of information made available varies by state, as some states are further along in the process than others. Some of the information related to pediatric and adult dental coverage requires the consumer to temporarily select an insurance company and then drill down on the web-page to gather information related to dental coverage and premiums.

Additionally, the states and the federal government continue to release guidance documents and regulations in advance of the October 1 deadline. ADEA will continue to keep members updated as ACA related guidance documents, informational bulletins, letters, and regulations are issued.

Duggan Dental