Plan Management New Proposed Rule Updates; Policies and Procedures: Application Evaluation Process
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1 Plan Management New Proposed Rule Updates; Policies and Procedures: Application Evaluation Process Arkansas Plan Management Advisory Committee December 14,
2 Agenda New Proposed Rules Overview Essential Health Benefit Rule Updates OPM Plan Rule Updates Policies and Procedures Application Evaluation Updates on development of policies and procedures SERFF Updates from NAIC Conference Evaluation Criteria and Checklists Outstanding Questions Next Steps 2
3 New Proposed Rules Overview November 26, 2012 Standards Related to Essential Health Benefits, Actuarial Value, and Accreditation November 26, 2012 Health Insurance Market Rules November 26, 2012 Incentives for Wellness Programs November 30, 2012 HHS Benefit and Payment Parameters December 10, 2012 Frequently Asked Questions 3
4 Essential Health Benefit Rule Updates Habilitative Services December 16, 2011 bulletin specified that habilitative services may be supplemented by the following process: Habilitative services would be offered at parity with rehabilitative services as defined by the benchmark, or As a transitional approach, plans would decide which habilitative services to cover and report to HHS. November 20, 2012 proposed rule adds an additional option under which States may define the set of habilitative services offered directly. Arkansas Health Committee was tasked with examining this option and proposing a solution. 4
5 Essential Health Benefit Rule Updates Pediatric Services The November proposed rule states that HHS interprets pediatric to mean individuals under age 19. Pediatric Vision December guidance allowed states to supplement benchmark based on Federal Employees Dental and Vision Insurance Program (FEDVIP) benefits. November proposed rule added the option of supplementing based on CHIP coverage. AR Kids B covers up to age 19. The following table compares AR Kids B coverage to the FEDVIP coverage. 5
6 FEDERAL VISION ARK VISION under 21 (B) Services Description Limitations Services Description Limitations Diagnostic Eye exam 1X per year Diagnostic Eye exam 1X per year, $10 copay Glasses/ Lenses Prescription glasses or contacts Lenses: single, conventional bifocal/trifocal, lenticular Frame Contact lens care Surgical evaluation if meets specific diagnoses Glasses/ Eye wear 1X per year, $10 copay Lenses 1 pair per year Lenses plastic or polycarbonate only 1 frame per every other year 1 pair per year in lieu of eyeglasses Eye glass repair Lost or broken eyewear replacement if originally purchased through program 1X only within benefit period, each additional pair req. prior authorization Other Low vision coverage needs preauthorization Contact lenses only if medically necessary, prior authorization Various lens subject to copay Other Eye prosthesis prior authorization types/coating Polarized lenses Polishing services prior authorization Medically necessary EPSDT program Covers services contact lenses medically necessary, Low vision evaluation 1 eval/5 years, follow that are ups (4 visits/5 years), permitted under allowance federal Medicaid regulations 6
7 Essential Health Benefit Rule Updates Pediatric Dental AR Kids B coverage was chosen as the supplement option for pediatric dental. AR Kids B covers children up to age 19 currently, in agreement with CCIIO s new stance on pediatric services. Prescription Drugs Pharmacy benefits are included under the chosen benchmark plan for Arkansas. Issuers must ensure coverage for 1) at least one drug in every category and class or 2) the same number of drugs per category and class as the benchmark, whichever is greater. 7
8 Office of Personal Management Rule Office of Personal Management (OPM) is required to contract with multi-state plans that will offer QHPs in every state. Essential Health Benefits Multi State Plans (MSPs) must offer benefits that are substantially equal to either: The EHB plan in each State where the product is offered; or One of the three largest Federal Employees benefit plans plus state mandates. Should the state choose to define the set of habilitative services required, MSPs will be required to follow that definition. 8
9 Office of Personal Management Rule Additional MSP Requirements Must comply with State laws as long as such laws are not inconsistent with the requirements of the Affordable Care Act and Public Health Services Act; Must comply with ACA-defined QHP certification standards; MSP will submit rate, benefit, and value information to OPM for review. OPM will conduct premium negotiations and review all submitted information; States will have the opportunity to review all plans following OPM review and work with OPM to resolve any disputes or inconsistencies. MSP must comply with standards set forth for reinsurance, risk adjustment, and risk corridors; and Must offer a child-only plan at the same plan level as other QHPs offered, consistent with requirements of State-specific QHPs. 9
10 P&P for Application Evaluation Progress Update: Met with Life and Health, Legal, Finance, and Exchange Divisions to define policies and procedures for application evaluation Next steps include completion of application and rate and form filing checklists and development of policies and procedures for oversight and monitoring functions CCIIO has indicated that there will be guidance on the QHP evaluation process (TBD) 10
11 P&P for Application Evaluation SERFF Updates from NAIC Conference March 28 th Release Date Included Features Required application data elements forthcoming Plans inside/outside exchange submitted once Accreditation information will be available in SERFF 11
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15 P&P for Application Evaluation Additional Screenshots and information can be found here: 15
16 P&P for Application Evaluation Application Review Checklists 16
17 P&P for Application Evaluation Outstanding Questions Awaiting clarification from SERFF regarding the separation of application review for plans inside and outside the exchange Awaiting clarification from CCIIO on cost-sharing reductions - how will states verify plan compliance with cost-sharing reduction requirements? Are states required to submit marketing materials/content to CCIIO for approval? 17
18 Next Steps Finalize checklists and procedures for application evaluation PMAC topic for 2013: Policies and Procedures Manual for oversight and monitoring functions 18
19 Public Consulting Group, Inc. 148 State Street, Tenth Floor, Boston, Massachusetts (617) , 19
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