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.
Updated: ACA Checklists for Departments of Insurance
Sally McCarty, David Cusano, Justin Giovannelli, and Max Farris, Georgetown University Health Policy Institute
Stemming from training at insurance departments in various State Network states, Georgetown University Health Policy Institute (Georgetown) has released updated form review checklists. These resources are designed to help insurance regulators effectively implement Affordable Care Act (ACA) provisions, regulations, and other guidance by ensuring that insurance forms submitted by carriers meet all the ACA requirements. These checklists are an update to the Georgetown ACA Implementation Toolkit for Departments of Insurance, which includes descriptions of the documents and how they can be utilized by states. Also included now is a Qualified Health Plan Issuer Certification Checklist. They are in writable Microsoft Word document form, allowing insurance regulators to simply download and modify to their state’s specifications. These checklists have been updated to reflect provisions in the HHS Final Rule on Benefit and Payment Parameters for 2016.
Catastrophic Plan Form Review Checklist – Updated 3/20/15
Individual Plan Form Review Checklist – Updated 3/20/15
Small Group Market Form Review Checklist – Updated 3/20/15
Stand Alone Dental Plan Form Review Checklist – Updated 3/20/15
QHP Issuer Certification Checklist – Updated 3/20/15
Additional tools for insurance departments include an Issuer Essential Health Benefits Crosswalk and Certification and a Mental Health Parity and Addiction Equity Act Issuer Checklist and Certification.