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.
On November 15, 2023, the Centers for Medicare & Medicaid Services released its proposed 2025 Notice of Benefit and Payment Parameters, the annual regulation which governs core provisions of the Affordable Care Act. This expert perspective focuses on aspects of the proposed rule likely to be of interest to state officials, including requirements for State-Based Marketplaces to align with the standards of the Federally Facilitated Marketplace, proposals for states to update essential health benefits, and initiatives to ease the eligibility and enrollment process for consumers.
This expert perspective summarizes CMS’ new Informational Bulletin and accompanying framework which together detail Medicaid coverage options for services that address the health-related social needs (HRSN) of Medicaid enrollees. The new guidance reiterates the importance of addressing HRSNs to improve access to care and health outcomes, and summarizes (and in some cases updates) multiple previous sources of CMS guidance on how HRSN services may be covered in Medicaid, including guidance on in lieu of services authority and on HRSN coverage in section 1115 waivers.
