FAQs and RFCs, Oh My!

The Department of Health and Human Services (HHS) released last week some materials of interest to those of us tracking the health insurance exchanges. Sorry, I should say health insurance “marketplaces.” First, for those interested in the future of the Basic Health Program (BHP) authorized under the Affordable Care Act, HHS has finally responded to states’ pleas for them to issue the necessary regulations…by letting everyone know they will NOT be issuing regulations, at least not any time soon. That’s right, last week, in a set of Frequently Asked Questions (FAQs), HHS said they will not be issuing final guidance on the BHP until 2014. Thus, any states interested in pursuing the BHP option will have to wait at least until 2015 before they can be operational.

However, HHS says they’re working with states who want to achieve the goals of the BHP (improving continuity of care for people whose income level changes may cause them to “churn” between Medicaid and private, subsidized coverage), by creating Medicaid “Bridge” plans. Unlike BHPs, there is no statutory basis for Bridge plans, and HHS hasn’t released any regulations or formal guidance on them, either. However, late last year, HHS released a set of FAQs indicating that a state could allow a Medicaid managed care insurer to serve as a “Bridge” plan – meaning they can offer coverage in the exchange to people transitioning off of Medicaid or the Children’s Health Insurance Program (CHIP). These plans would not have to meet the “guaranteed issue” requirements of other exchange plans, because they would only be open to those leaving Medicaid and CHIP. However, these plans would allow people to stay with the same provider network they had when they were eligible for Medicaid.

In other exchange news, HHS last week released a “Request for Comment” (RFC), regarding their plan to collect information from insurance agents and brokers as a prerequisite to registering with the federally facilitated exchanges (FFEs). In order to register with the FFE, brokers will have to provide their licensure status, as well as any appointments they have with health insurers. In addition, HHS will collect identifying information in order to track whether registered agents/brokers complete the required exchange training program. These training programs and accompanying exams are designed to ensure that agents/brokers have the necessary expertise and information to connect people and small businesses with coverage in the exchange. HHS will also use the information for ongoing oversight and monitoring of agents and brokers.

And last but not least, this Friday is the deadline for states to submit their declaration letters and Blueprints for becoming “partnership” exchanges. And we’re expecting some final rules soon on the minimum essential health benefits, the risk mitigation programs, and the 2014 market rules. Read about all of the above and more here, at CHIRblog!

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