Arkansas Health Insurance Marketplace

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1 Independent Accountant s Report on Applying Agreed-Upon Procedures June 30, 2018

2 Independent Accountant s Report on Applying Agreed-Upon Procedures Little Rock, Arkansas We have performed the procedures enumerated in this report, which were agreed to by Arkansas Health Insurance Marketplace (Exchange), related to the processes and internal controls over the compliance with specified financial and programmatic requirements of the Centers for Medicare & Medicaid Services (CMS) of the Marketplace for the year ended June 30, 2018, solely to assist the Exchange in meeting the financial and programmatic requirements as specified by CMS for completion of certain aspects of the Exchange s 2018 State-based Marketplace Annual Reporting Tool (SMART) submission. The management of is responsible for its compliance with these requirements. The sufficiency of these procedures is solely the responsibility of the parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures described in this report either for the purpose for which this report has been requested or for any other purpose. Because the Exchange utilizes the federal platform, our scope was limited to the sections of 45 Code of Federal Regulations (CFR) part 155 applicable to the structure of the Exchange. The findings obtained are described below. Subpart C General Functions of an Exchange 45 CFR part Functions of an Exchange We discussed the federal requirements in 45 CFR 155 with the Exchange s chief financial officer in order to gain an understanding of the Exchange s operations and the applicability of the requirements. We viewed a Memorandum of Understanding (MOU) in place between the Exchange and Arkansas Insurance Department (AID) that provides details on the responsibilities of the two entities. 45 CFR part Consumer assistance tools and programs of an Exchange We discussed the federal requirements of 45 CFR with the process owners of key roles to determine that they have adequate understanding of the related requirements and that the Exchange-required information was available to consumers.

3 Page 2 We viewed the MyARInsurance website maintained by the Exchange and observed that the following information is displayed: the toll-free hotline number. We observed the personnel working the toll-free hotline line and reviewed call center scripts that convey how consumers are directed to the appropriate support entities for enrollment. 45 CFR part Ability of States to permit agents and brokers to assist qualified individuals, qualified employers, or qualified employees enroll in QHPs (Qualified Health Plans) We discussed the federal requirement in 45 CFR with the process owners of key roles and determined that they pose adequate overall knowledge of the related requirements. We obtained and read training materials over privacy, security and compliance to determine that the Exchange has training materials available to train and register agents or brokers assisting in enrolling others in QHPs. Subpart K Exchange Functions: Certification of Qualified Health Plans 45 CFR part Certification standards for QHPs We discussed the federal requirements with process owners of key roles and documented their understanding of the certification standards and responsibilities for ensuring compliance. We obtained and read the MOU in place between the Exchange and AID that provides details on the responsibilities of the two entities. We obtained and read the Act to determine that it provides for the implementation of procedures and criteria for the certification of health benefit plans. We noted that the notice of benefit and payment parameters, the AID bulletin and the letter to issuers were all available online.

4 Page 3 45 CFR part Certification process for QHPs have an understanding of the certification process and responsibilities for ensuring compliance. We viewed the Health Insurance Rate Review (HIRR) and the AID websites for certified QHPs. We viewed the timeline outlined by AID to become certified and the checklist created to assist issuers in the submission of a QHP. 45 CFR part QHP issuer rate and benefit information have an understanding of the process for handling and updating rate and benefit information. We selected one rate increase processed for BlueCross BlueShield (BCBS) in May 2018 posted on the website and viewed documentation that evidences review and approval by AID of the requested increase. We obtained and read the Rating Filing Summary and Summary of Benefits and Coverage to determine that they included rates, covered benefits, and cost-sharing requirements (co-pays or co-insurance). 45 CFR part QHP certification standards related to advance payments of the premium tax credit and cost-sharing reductions have an understanding of the processes in place to achieve compliance with the related requirements. We viewed the System for Electronic Rate and Form Filing (SERFF) website for exchange of rate allocation information between AID and CMS/Health and Human Services (HHS) to determine that an exchange process is in place to administer advance payments of the premium tax credit and cost-sharing reductions.

5 Page 4 45 CFR part Transparency in coverage We inquired of the process owners of key roles and document AID s process for collecting information from QHP issuers. We read the Arkansas version of the Individual Form Review QHP Checklist and noted the checklist covered the following specific items related to the regulations: plan enrollment, rates, coverage of benefits, cost-sharing information, premiums, reporting and transparency requirements. We viewed a Rate Filing Summary and Summary of Benefits and Coverage for one QHP on the Health Insurance Rate Review (HIRR) website and noted that the QHP issuer has made costsharing information available. 45 CFR part Establishment of Exchange network adequacy standards have an understanding of the review process in place to ensure that QHP network adequacy standards are met. We viewed the Arkansas version of the Individual Form Review QHP Checklist and noted that the Exchange has a process in place to monitor whether the provider network of each QHP meets the standards specified in Section CFR part Service area of QHP We discussed the federal requirements with process owners of key roles and documented AID s processes for evaluating service area adequacy. We obtained and read the Arkansas version of the Individual Form Review QHP Checklist and noted that it addresses service areas.

6 Page 5 45 CFR part Stand-alone dental plans We inquired of the process owners of key roles and documented the dental plans offered through the Exchange. We compared the plan designs to the general requirements in Section (a) and noted dental plans offered through the Exchange were allowable under the federal regulations. Using the Anonymous Shopping tool, we viewed the Summary of Benefits and Coverage for QHPs on the Exchange website and noted dental plans offered were consistent with our documentation of stand-alone dental plans offered through the Exchange. 45 CFR part Recertification of QHPs We inquired of the process owners of key roles and documented the recertification process. We obtained and read the Arkansas version of the Individual Form Review QHP Checklist used for the certification/recertification process and noted that the Exchange has established a process for recertification of QHPs. For one recertification selected haphazardly, we viewed a QHP recertification processed in May 2018 on the HIRR website. We viewed the Excel-based plan certification template available to carriers on the SERFF website and noted that the Exchange has established a process for recertification of QHPs. We observed the recertification selected above was approved and processed prior to the September 15 deadline. 45 CFR part Decertification of QHPs We inquired of the process owners of key roles and documented the decertification and appeals process and required notices. We inquired with a representative of AID who represented that there were no decertifications of QHPs by AID during 2018.

7 Page 6 This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants and the standards for attestation engagements contained in Government Auditing Standards, issued by the Comptroller General of the United States. We were not engaged to and did not conduct an examination or a review, the objective of which would be the expression of an opinion or conclusion, respectively, on compliance with the specified requirements. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you. The purpose of this report is solely to assist the Exchange in meeting the financial and programmatic requirements as specified by CMS for completion of certain aspects of the Exchange s 2018 SMART submission. Accordingly, this communication is not suitable for any other purpose. Little Rock, Arkansas January 15, 2019

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