ACA Implementation Toolkit for Departments of Insurance
Georgetown University Health Policy Institute – Mila Kofman, Katie Dunton and Sally McCarty
In order to assist states in accomplishing tasks related to insurance market reforms and certification and management of qualified health plans, the Georgetown University Health Policy Institute has developed a toolkit for insurance departments. Many Affordable Care Act (ACA) implementation issues fall squarely within existing state insurance regulatory functions. This toolkit is designed to help insurance regulators effectively implement ACA provisions, regulations, and other guidance by planning and allocating resources for and conducting many of the plan management functions associated with successful exchange implementation.
This toolkit includes several self-audits, templates, and checklists to help departments of insurance work in concert with other state agencies in ascertaining the appropriate locus of exchange related functions. Further, the toolkit can help state agencies operationalize those responsibilities. The toolkit will be updated periodically with additional resources and uploaded to www.StateNetwork.org. The list of specific resources and descriptions follow:
Form Review Checklist, Model Notices and Examples The form review checklist is a document for insurance regulators to use in reviewing forms associated with products (insurance contracts, policies, certificates of coverage, etc.) filed by issuers for approval prior to offering the products to consumers. The document in the toolkit serves as an example of the Form Review Checklist. To fill out the form, download the editable file here.
ACA Insurance Self-audit The self-audit is a chronological, step-by-step checklist that gives states a guide as they analyze their insurance laws, rules and regulations, etc. for compliance with the ACA.
Exchange Functions Checklist The exchange functions checklist is a tool to help departments of insurance work with their health insurance exchanges to identify and document functions they may currently perform and to determine which entities should perform these functions going forward.
Work Plan Template The work plan template is a matrix designed to allow state officials to identify tasks that have been completed, what is on-going, and what needs to begin for plan management functions.
Qualified Health Plan (QHP) Certification ‘Cheat Sheet’ This summary of QHP provisions from federal guidance is designed as a quick reference for states providing a high level outline of requirements including certification of and minimum standards for QHPs.
Essential Health Benefits (EHB) Planning Template This template provides the key decisions and considerations states need to address in choosing an EHB benchmark plan and the related work to operationalize that decision once it is made.
At the end of the public health emergency (PHE), people currently enrolled in Medicaid and the Children’s Health Insurance Program are at risk of losing their coverage unless state Medicaid/CHIP agencies take steps to update enrollee mailing addresses and other contact information. This expert perspective examines the information technology system, policy, and operational strategies states can consider to update key enrollee contact information to ensure eligible enrollees are able to keep or transition to new affordable health coverage at the end of the PHE.
On October 7, the U.S. Departments of Health and Human Services (HHS), Treasury, and Labor (DOL) and the Office of Personnel Management (OPM) published a third rule implementing the No Surprises Act (NSA), the comprehensive federal law banning balance bills in emergency and certain non-emergency settings beginning January 1, 2022. This third rule, an interim final rule, provides details on the independent dispute resolution process (IDR), good faith estimates for enrollees on the cost of services, the dispute resolution process for uninsured patients, and external review. This expert perspective summarizes the provisions of the IFR and notes particular implications for state regulators.
