On January 27, 2023, the Centers for Medicare & Medicaid Services released a State Health Official (SHO) letter, “Medicaid Continuous Enrollment Condition Changes, Conditions for Receiving the FFCRA Temporary FMAP Increase, Reporting Requirements, and Enforcement Provisions in the Consolidated Appropriations Act, 2023.” The SHO letter is the second in a series of guidance related to section 5131 of the Consolidated Appropriations Act, 2023 (CAA), which established a fixed end date for the Medicaid continuous coverage requirement, a gradual phase-down for the enhanced federal match, and new guardrails for mitigating coverage loss for individuals who continue to be eligible. This expert perspective reviews the additional detail and operational expectations of states during the unwinding of Medicaid continuous coverage as laid out in the SHO letter.
Rate Development, Filing and Review – A Compilation of Guidance and Expectations for 2015 Rates Webinar
Departments of insurance and insurers are currently preparing for the next round of rate development, filing and review. Rates for 2014 were developed based on considerable speculation on the expected impact of the ACA market reforms on the number and health risk of individuals who would enroll. Early enrollment information will be available for the 2015 rate development and review process, however, robust health risk information may still be unavailable.
Additionally, CMS has released a variety of guidance that impacts plans that will be offered in 2015 and their associated rates, including the allowance for continuation of 2013 policies that are not compliant with 2014 market reforms, changes to the 3Rs, and additional clarity on rate development methodology. The State Health Reform Assistance Network hosted a webinar that explored the considerations for 2015 rate development, filing and review based on a compilation of CMS guidance and insights from Wakely Consulting Group actuaries. The webinar was intended for department of insurance staff and other stakeholders interested in the rate filing and review process for plan year 2015.
The webinar slides can be found at the “download” button and a webinar recording can be found here.