The deadline for health insurance issuers to submit applications for the Office of Personnel Management’s (OPM) multi-state plan program came and went on March 29^th with little fanfare. However, as more and more information comes out about which issuers have submitted plans for exchange certification across the country, we at CHIR have been wondering, where are the multi-state plans?

Here’s what we know:

• According to a recent White House memo, OPM is currently reviewing more than 200 potential plans. The memo also reiterated that multi-state plans will be offered in at least 31 states in 2014.
• At least four states – Arkansas, Maryland, Michigan, and Montana – have indicated that they expect to have a multi-state plan on their exchange in 2014. Notably, these states are pursuing a range of exchange models (Arkansas and Michigan are working with the federal government to operate a state partnership exchange, Maryland is establishing a state-based exchange, and Montana is conducting plan management on behalf of its federally facilitated exchange).
• In Arkansas, Michigan, and Montana, Blue Cross Blue Shield will be offering the multi-state plan. In all three states, as well as in Maryland, the state Blue Cross Blue Shield companies already dominate the market and have submitted plans for exchange certification as well. It is unclear how much variation will exist between the state Blue Cross Blue Shield plans and the multi-state plans.
• In Arkansas, both the state Blue Cross Blue Shield plans and the multi-state Blue Cross Blue Shield plans will be offered statewide, despite OPM giving flexibility to multi-state issuers in this respect.
• Multi-state plans could still show up in states that have announced a preliminary list of exchange applicants. Remember that once OPM certifies a multi-state plan, it is “deemed” certified for participation in all the exchanges. While OPM has said that it plans to coordinate with the states and keep them apprised of contract negotiations, it is not bound by exchange certification timelines.

Here’s what we don’t know:

• Whether the multi-state plans in the four known states will only be available on the individual exchange, or will also be sold to small groups.
• Whether any issuers besides Blue Cross Blue Shield will participate in the multi-state plan program and, if so, which ones. Both Maryland and Arkansas hinted that one or more additional multi-state issuers may still enter their market. And, if more issuers do join the program, we are curious whether they will choose the same or a different selection of states from Blue Cross Blue Shield to enter in 2014.

We hope more information on the multi-state plan program will be released soon and will be sure to keep you posted on key developments.

(NOTE: This blog post was updated on June 7, 2013 to add newly released information about an application for a multi-state plan in Michigan.)