This issue brief, prepared by Manatt Health Solutions, summarizes federal policy guidance and outlines requirements, options and key considerations for State-based Exchanges (SBEs) on Exchange premium collection functionality. Exchanges organized pursuant to the Affordable Care Act (ACA) have certain requirements and several options for premium collection services for small businesses and individual consumers purchasing qualified health plans (QHPs) in 2014. While collection functionality is required in Small Business Health Options Program (SHOP) Exchanges, it is an optional service in the individual Exchanges. This brief explores the policy and operational considerations that SBEs face related to the three options for premium collections functionality:
■ The Exchange performs all premium billing and collections functions for SHOP and individual market consumers, with the option for people to pay their issuer directly, as required under the ACA;
■ The Exchange bills and collects the initial premium payment to effectuate real-time QHP enrollment; QHP issuers bill for all other months of enrollment; or,
■ The Exchange performs premium collection in the SHOP Exchange only, as required by law; QHP issuers perform the function for individual QHP enrollees.
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.