Regulatory Analysis | Aug 11, 2011

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.

 


Expert Perspectives

December 7, 2023

State Reporting to Monitor the Unwinding of the Medicaid Continuous Coverage Requirement

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.

State-Based Marketplace Transition Data During the Unwinding

Given the potential to reduce coverage losses during the unwinding, there is intense interest in data that monitors transitions between Medicaid and Marketplace coverage. State-Based Marketplaces (SBMs) that operate their own eligibility platform should consider releasing available data on Marketplace transition outcomes. This expert perspective includes an interactive map with links to SBMs reporting Marketplace transitions, a table of the indicators that states are reporting on, and select data highlights. The expert perspective also highlights recommendations for SBMs when presenting unwinding data, such as providing context and making the data easy to use. SHVS will continue to update this EP as more SBMs publish unwinding data.

December 1, 2023

The Proposed 2025 Notice of Benefit and Payment Parameters: Implications for States

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.