Expert Perspectives

Nov 16, 2021 

More States Looking to Section 1332 Waivers

In the absence of federal legislation, states are actively seeking tools to reform their health care systems. While 1115 waivers rightly get a lot of attention, because of their ability to reshape state Medicaid programs, the Affordable Care Act’s Section 1332 waivers continue to be a promising avenue for states to stabilize their health insurance marketplace. SHVS is tracking state activity and has many resources, including a template, for states interested in pursuing a Section 1332 waiver.

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Oct 25, 2021 

State Policy and IT System Strategies to Prepare for PHE Unwinding: Updating Medicaid Enrollee Address Information and Responding to Returned Mail

At the end of the public health emergency (PHE), people currently enrolled in Medicaid and the Children’s Health Insurance Program are at risk of losing their coverage unless state Medicaid/CHIP agencies take steps to update enrollee mailing addresses and other contact information. This expert perspective examines the information technology system, policy, and operational strategies states can consider to update key enrollee contact information to ensure eligible enrollees are able to keep or transition to new affordable health coverage at the end of the PHE.

Oct 22, 2021 

The No Surprises Act Interim Final Rule on Dispute Resolution, Uninsured Protections, and External Review: Implications for States

On October 7, the U.S. Departments of Health and Human Services (HHS), Treasury, and Labor (DOL) and the Office of Personnel Management (OPM) published a third rule implementing the No Surprises Act (NSA), the comprehensive federal law banning balance bills in emergency and certain non-emergency settings beginning January 1, 2022. This third rule, an interim final rule, provides details on the independent dispute resolution process (IDR), good faith estimates for enrollees on the cost of services, the dispute resolution process for uninsured patients, and external review. This expert perspective summarizes the provisions of the IFR and notes particular implications for state regulators.

Oct 13, 2021 

ACA Marketplaces Well-Positioned for Strong 2022 Open Enrollment Season

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.