The last time CHIRblog checked in on SERFF activities was late November, shortly after the U.S. Department of Health and Human Services (HHS) had released proposed standards for insurers to submit proposed premium rates and forms to state and federal regulators. The hotel ballroom was standing room only, with state insurance officials, insurers, consumer representatives, and the media all eager to learn more about how plans would become certified to participate in the new health insurance exchanges.
The latest gathering for SERFF’s series of Health Insurance Exchange Plan Management Forums, held on April 9 in Houston, Texas, was equally well-attended, with participants eager for operational details and updates. Officials from HHS’ Center on Consumer Information and Insurance Oversight (CCIIO) were also present and, now that their rulemaking is largely complete, available to answer dozens of questions from regulators and insurers. Before I share a few highlights from the meeting, a little background might be helpful.
SERFF (System for Electronic Rate and Form Filing), operated by the National Association of Insurance Commissioners (NAIC), is the system that most state Departments of Insurance (DOI) use to collect information from insurers about proposed premium rates and benefits. Since the summer of 2011, the SERFF team has been developing a system that would allow insurers to submit the information necessary to determine whether they meet the certification standards for participation on the health insurance exchanges. In general, states operating their own exchange, and states partnering with the federal government to conduct plan management activities, will use SERFF to conduct the certification and oversight of participating insurers. Insurers in states that have defaulted to a federally facilitated exchange (FFE) will use a different, federal system, called HIOS (Health Information Oversight System).
Update from SERFF Team
- The SERFF Plan Management system (version 6.0) was released the evening of March 28th. It was characterized as an “uneventful” launch. To date, 339 plans have been preliminarily filed within the system, and there was some concern about the slow pace. However, the SERFF team expects submissions to accelerate as the filing deadline (April 30) approaches.
- SERFF has trained 188 different insurance companies on the SERFF plan management system and officials from 48 states.
- SERFF will update the system in May (version 6.1) to add new functionality, such as the ability to push data from SERFF to the health insurance exchanges.
- SERFF will update the system again later in the year to add functionality to allow for plans to be recertified and, where necessary, decertified. SERFF expects that plans will have to be filed for recertification in early to mid-2014, for the 2015 plan year. They noted, “No one wants to relive the timeframes we’ve been under this year.”
- The SERFF team is also preparing for the likelihood that states will transition between different exchange models going into 2015. They’re estimating that roughly 2/3 of states will change models. FFE states may become partnership states. Partnership states may become state-based exchange states. And, it’s possible that some states currently planning to operate their own exchange won’t meet all the necessary milestones and timeframes, and default to FFE or partnership status.
- SERFF staff also addressed some important enforcement issues, such as:
- Use of NAIC’s systems to track and verify the licensing and/or certification of navigators.
- Validation of whether insurance agents or brokers are licensed.
- Collection and tracking of consumer complaints about brokers.
- Verification of an insurance company’s state license, and whether they are “in good standing” with the state.
- Collection and tracking of consumer complaints about their health plan. They noted that the existing NAIC database of consumer complaints probably doesn’t record the necessary level of detail. While it won’t be a long term solution, it is all that’s available for the short term.
Update from CCIIO Team
The CCIIO rate review and plan management team spent about an hour taking questions from DOI officials and insurance company representatives. The questions were all pretty granular. A few stood out, such as several questions regarding the selection of geographic rating areas in the states and how they factor into premium rates. CCIIO staff reminded the audience that geographic rating must be counted as one rating factor per insurer per geographic area. They also noted that the geographic location is based on where the policy is sold, not where the policyholder resides. This is relevant for group policies, because employees often reside in a different rating area than their place of employment. It also could be an issue for family policies, if children live away from home.
A representative from the D.C. exchange asked how they will integrate Members of Congress and their staff into the exchanges (CCIIO’s answer: there has some discussion of this between CCIIO and the Office of Personnel Management, but no details yet). One regulator asked whether CCIIO was concerned about their IT system crashing if they get a big crunch of filings at the end of the month. CCIIO noted that they’d learned some lessons from the Medicare Part C and D experiences, and believed they could handle the anticipated volume.
For more information about the meeting, and upcoming SERFF Plan Management forums, check out their website, here.