Author Archive: Justin Giovannelli

Broker Commissions for Mid-Year Enrollment in the Marketplaces: Options for State Marketplaces and Insurance Regulators to Prevent Discrimination

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Several insurers have eliminated broker commissions for mid-year marketplace enrollment. In a new Expert Perspective for the State Health & Value Strategies project, CHIR’s Justin Giovannelli looks at the consequences of cutting broker commissions for special enrollment periods, including risk of coverage losses, market instability, and potential violations of federal nondiscrimination rules.

Ensuring the Adequacy of ACA Marketplace Plan Networks

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Following the Trump administration’s decision to roll back federal network adequacy standards for Affordable Care Act marketplace plans, the Biden administration signaled it will soon resume oversight, proposing new, quantitative standards as well as proactive compliance procedures. In a new post for the Commonwealth Fund’s To the Point blog, CHIR’s Justin Giovannelli examines current state and federal approaches to network adequacy, and what would change under the new standards proposed by the Biden administration.

A Permanent Boost to Federal Premium Assistance Could Change State Approaches to ACA 1332 Waivers

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The American Rescue Plan temporarily increases the availability and generosity of federal premium assistance for people who obtain coverage through the ACA marketplaces. Were Congress to make these premium subsidy enhancements permanent, states would have more breathing space to address other barriers to care, potentially with support from an ACA Section 1332 waiver. In a new work for The Commonwealth Fund, Justin Giovannelli examines how a permanent boost to federal subsidies could give states new and different opportunities to help their residents using the ACA’s waiver program.

The Administration Tried to Make It Easier for States to Waive ACA Rules: Will Any Take the Plunge?

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Recent federal guidance made significant changes to the ACA’s section 1332 waiver program in order to give states greater leeway to sidestep ACA rules. But the move has triggered questions about whether the waiver options the Trump administration is touting are practical for states, or even legal. In a new work for The Commonwealth Fund, Justin Giovannelli and JoAnn Volk examine how states are approaching ACA waivers in the wake of the federal policy change.

Trump Administration Hands States Another Tool for Dismantling Preexisting Condition Protections

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Last week, the Trump administration issued long-anticipated guidance regarding the ACA’s Section 1332 “innovation waiver” program. The guidance breaks dramatically with past policy and, arguably, with the statute it purports to interpret, inviting states to undermine coverage for people with preexisting conditions. CHIR’s Justin Giovannelli analyzes the guidance and its implications.

The Experiences of State-Run Insurance Marketplaces That Use HealthCare.gov

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Whether their exchange is state-based or federally facilitated, many state policymakers are seeking ways to realize the advantages of a state-run marketplace model while minimizing, so far as possible, the financial and operational burdens of building or maintaining one. In a new issue brief for The Commonwealth Fund, CHIR researchers explore the experiences of four states that established their own exchanges but have operated them with support from the federal HealthCare.gov eligibility and enrollment platform.

The opinions expressed here are solely those of the individual blog post authors and do not represent the views of Georgetown University, the Center on Health Insurance Reforms, any organization that the author is affiliated with, or the opinions of any other author who publishes on this blog.