Analysis of the Trump Administration’s Proposed Short-Term Health Plan Rule: Implications for States
Georgetown University’s Center on Health Insurance Reforms and Manatt Health
The Secretaries of Health and Human Services, Treasury, and Labor released a proposed rule to implement the President’s October 12, 2017 executive order calling for expanded availability of short-term limited duration health plans that do not have to comply with Affordable Care Act standards. The proposed rule would relax current federal rules by allowing short-term plans to be sold for a duration of up to 12 months. It also modifies required consumer disclosures about these products. State Health and Value Strategies hosted a webinar, together with experts from Georgetown University’s Center on Health Insurance Reforms and Manatt Health and others, that reviewed the proposed rule and its implications for state insurance markets and consumers. The webinar also flagged specific areas in which the federal agencies are asking for input from states and other stakeholders.
We also have an expert perspective up on our website by Sabrina Corlette, JoAnne Volk and Justin Giovannelli from Georgetown’s Center on Health Insurance Reforms that examines the proposed rule in detail and provides options for state responses to short-term limited duration health plans.
On December 6, the Centers for Medicare & Medicaid Services published and made effective an interim final rule (IFR) with comment period regarding states’ ongoing unwinding efforts to redetermine eligibility for all Medicaid enrollees nationwide. This expert perspective summarizes the IFR, which interprets and implements the state reporting requirements and CMS enforcement authorities that Congress enacted last winter in the Consolidated Appropriations Act of 2023.
The 11th annual open enrollment period (OEP) is underway, providing consumers with an opportunity to enroll in health coverage for plan year 2024 through the Affordable Care Act Marketplaces. To support consumers during this OEP, State-Based Marketplaces (SBMs) are innovating to make health coverage more affordable and easier for consumers to enroll. This expert perspective highlights new initiatives being implemented by SBMs during the plan year 2024 OEP, including establishing or improving state subsidy programs to reduce out-of-pocket costs, expanding coverage for undocumented populations, or implementing policies to improve the enrollment process.
As the unwinding of the Medicaid continuous coverage requirement continues, both states and the federal government are tracking and monitoring the impacts of the resumption of eligibility redeterminations and disenrollments. Given the time-lags and caveats of CMS data, many states are publishing their own state data dashboards. To date, 46 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 reporting, as well as a table tracking the unwinding indicators and disaggregated data that states are reporting on. SHVS will continue to update this EP as more states publish their unwinding data.