With the Patient Protection and Affordable Care Act’s (ACA’s) ninth open enrollment period (OEP) set to launch in less than a month, the ACA Marketplaces are seeing record enrollment numbers with more generous subsidies, new carrier competition, and a relatively stable rating environment. At the same time, there is uncertainty with the trajectory of the COVID-19 pandemic and medical costs trending upward as the economy recovers, albeit at an uneven pace. These trends have made for a challenging rate review process in the 47 states plus the District of Columbia (D.C.) that conduct their own ACA rate reviews of carrier-proposed rates using federal review standards. State announcements of 2022 rates have trickled out at a slower pace than in prior years, and it is likely that many states will not publish their approved rates until the beginning of open enrollment. As always, state rate results vary widely and, even within states, there often are substantial variations among carriers and across different regions in geographically diverse states. With these caveats, this expert perspective highlights some observations about the factors that are impacting rate changes this year and the kind of variations that exist among states.
HRA Regulations: State Implications and Responses
State Health and Value Strategies
On Friday, June 21 at 1:00 p.m. ET State Health and Value Strategies hosted a webinar for state officials with technical experts to discuss the implications of the health reimbursement arrangements (HRA) rule and possible state responses. The webinar featured Jason Levitis, who led ACA implementation at the U.S. Treasury Department, as well as experts from Georgetown University’s Center on Health Insurance Reforms and from Manatt Health.
The U.S. Departments of Health and Human Services, Labor, and Treasury released final regulations easing the rules governing HRA and other account-based, tax-preferred health care on June 13. The final rule represents the third of the three policy changes initiated by the October 12, 2017 Executive Order, which also called for easing the rules on short-term limited-duration coverage and association health plans. Like those changes, the HRA rule could have profound implications for health insurance markets, consumers, and Marketplaces. The rule is effective in 2020, which raises important considerations about Marketplace readiness and potential tax consequences for individuals.