In the absence of federal legislation, states are actively seeking tools to reform their health care systems. While 1115 waivers rightly get a lot of attention, because of their ability to reshape state Medicaid programs, the Affordable Care Act’s Section 1332 waivers continue to be a promising avenue for states to stabilize their health insurance marketplace. SHVS is tracking state activity and has many resources, including a template, for states interested in pursuing a Section 1332 waiver.
HHS Proposed Rules on Exchange Implementation Requirements
Manatt Health Solutions – Deborah Bachrach, Patricia Boozang, Melinda Dutton and Alice Lam
Health insurance exchanges are the vehicle through which millions of Americans will gain access to coverage beginning in 2014. The U.S. Department of Health and Human Services (HHS) released its initial proposed rules on exchange implementation on July 11, 2011. This issue brief, authored by Manatt Health Solutions, highlights the provisions of the proposed rules that will impact state planning and implementation of exchanges. It summarizes they key provisions across a number of broad categories including exchange establishment, exchange functions, individual enrollment, the Small Business Health Options Program (SHOP), Qualified Health Plan (QHP) accreditation and certification, enrollment periods and effective dates in the individual market, and the exchange establishment process and criteria. The brief also identifies areas in the proposed rules that provide new insight on exchange development, for example the introduction of a new “state partnership model” for exchange development.