Analysis of HHS Proposed Rules On Reinsurance, Risk Corridors and Risk Adjustment
Wakely Consulting Group – Ross Winkelman, Julie Pepper, Patrick Holland, Syed Mehmud and 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 insurance exchanges. To ensure robust markets, exchanges must have in place processes for mitigating the financial risk to insurers associated with enrolling individuals with diverse health care needs. The intention is for issuers to compete for customers based on cost and quality, rather than attracting the healthiest, lowest-cost enrollees. The U.S. Department of Health and Human Services released its initial proposed rules on Standards Related to Reinsurance, Risk Corridors and Risk Adjustment on July 11, 2011. This issue brief prepared by Wakely Consulting Group summarizes the proposed rules and provides perspective on the implications for states as they integrate risk mitigation into the exchange implementation process. The brief highlights the application of the different risk mitigation programs (risk adjustment, reinsurance and risk corridors) to the various insurance marketplaces (individual and small group, both inside and outside the exchange) and includes next steps for states and insurers. The summary of these rules, as well as the authors’ analysis of their implications, is meant for policy-makers and state officials familiar with these complex issues.
Building on this proposed rules analysis, Wakely Consulting Group 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.
As states are working diligently to operationalize the unwinding of the Medicaid continuous coverage requirement, State Health and Value Strategies has been tracking the creative strategies states are implementing to minimize coverage losses. This expert perspective highlights all the hard work states are engaged in and spotlights innovative strategies other states may want to consider adopting. SHVS will continue to track and share state efforts to support coverage through the unwinding period. If your state is implementing a new effort to reach enrollees, or if you have questions about how you can implement an example included in this EP, please be in touch.
The unwinding of the Medicaid continuous coverage requirement represents the largest nationwide coverage transition since the Affordable Care Act, with significant health equity implications. Given the intense focus on coverage transitions during the unwinding, some states are publishing their data to monitor progress. To date, 44 states (including the District of Columbia) have released unwinding data in either an interactive dashboard or static pdf format, or are making public their required CMS Monthly Unwinding Data reports. This expert perspective includes an interactive map with links to state dashboards and reports to CMS. SHVS will continue to update this EP as more states publish their unwinding data.
States are traditionally laboratories for policy innovation and the 2023 legislative session was no exception. The expansion of health coverage was a major priority for states, particularly for low-income populations, children, postpartum individuals and individuals of undocumented status. As the high cost of care continued to be a major barrier for consumers, states bolstered their efforts to enhance healthcare affordability. States also used the 2023 legislative session as an opportunity to study system innovations to expand health coverage and affordability. This expert perspective explores these trends in state healthcare policy reflected in innovative legislation enacted this year.
