Analysis of HHS Final Rules On Reinsurance, Risk Corridors And Risk Adjustment
Wakely Consulting Group – Ross Winkelman, FSA, MAAA, Julie Peper, FSA, MAAA, Patrick Holland, Syed Mehmud, ASA, MAAA, James Woolman
Under the Affordable Care Act (ACA) much of the expanded coverage will be provided through health insurers offering products on the new health benefit exchanges (exchanges). By compensating issuers for the risks related to the individuals they enroll, provisions related to reinsurance, risk corridors and risk adjustment are designed to lessen the financial risk issuers and exchanges will face under the ACA. These programs will mitigate the impact of adverse selection and encourage issuers to compete based on cost and quality, rather than attracting the healthiest, lowest-cost enrollees. On March 16, 2012, the U.S. Department of Health and Human Services (HHS) issued final rules, titled “Patient Protection and Affordable Care Act; Standards Related to Reinsurance, Risk Corridors and Risk Adjustment.” This research brief prepared by Wakely Consulting Group summarizes the final rules, highlights the changes from the proposed rules of July 11, 2011, and provides Wakely’s perspective on the implications. It is intended for policymakers and state officials familiar with the complexities underlying these issues.
Wakely Consulting Group has also prepared a Work Plan that serves as an outline for state officials on the decisions and actions necessary to implement the risk adjustment and reinsurance provisions of the ACA.
Reinsurance is a long-standing tool for stabilizing health insurance markets and reducing premiums, and has played an important role in the success of the Affordable Care Act’s individual market as part of section 1332 state innovation waivers. Reinsurance increases affordability for consumers ineligible for the premium tax credit (PTC). However, the effects on PTC recipients are smaller, mixed, and have received little attention. This expert perspective summarizes recent research which raises questions about the impact of reinsurance programs on PTC recipients, and highlights related considerations for state policymakers.
On August 29, 2024, the Centers for Medicare & Medicaid Services (CMS) released aCMCS Informational Bulletin (CIB) and accompanyingslide deck to support states facing renewal backlogs. With this guidance, CMS is providing states additional time—until December 31, 2025—to complete Medicaid and CHIP eligibility renewals, address persistent backlogs in processing redeterminations, and achieve compliance with federal renewal timeliness requirements. This expert perspective provides an overview of the CIB.
