Tag Archive: federally-facilitated exchanges

SCOTUS should issue ruling in King v. Burwell ASAP

The U.S. Supreme Court should issue its ruling in King v. Burwell regarding the availability of advance premium tax credits in the nearly three dozen states where the federal government operates state health benefit exchanges as soon as possible. Waiting to issue its decision at or near the expiration of its current term at the end of June will produce months of needless uncertainty adversely impacting the policy planning of the states with federally facilitated exchanges (FFEs), particularly given that many of their legislatures are in session now and considering contingencies including establishing state-based exchanges should the subsidies be ruled illegal in those states.

If the subsidies are found to be contrary to the Patient Protection and Affordable Care Act — even though there’s at least an even chance they will not — states will need sufficient time to authorize and set up their own exchanges and select exchange qualified health plans prior to the start of plan year 2015 open enrollment on November 1. Health plan issuers also need to know if the subsidies will be available in order to make decisions as to what if any plans they will offer in the affected FFE states. Finally, with Congress trapped in partisan gridlock, there is little likelihood of a quick fix from the legislative branch of the federal government if the subsidies are cut off in the FFEs. It’s up the the judiciary to end the uncertainty. A rapid ruling would also be consistent with the high court’s expedited decision to hear the case before a full split could develop among the U.S. circuit courts of appeal.

 


Need a speaker or webinar presenter on the Affordable Care Act and the outlook for health care reform? Contact Pilot Healthcare Strategies Principal Fred Pilot by email fpilot@pilothealthstrategies.com or call 530-295-1473. 

Utah: Medicaid expansion would save large employer penalties, use SHOP exchange for individual plans

Approval of its proposed Healthy Utah Medicaid expansion program would allow large employers of low wage workers avoid penalties when those workers enroll in subsidized individual health plans though the state’s health benefit exchange, according to a document describing the program. The proposed 3-year pilot program is pending approval of a Section 1115 waiver of Medicaid rules from the U.S Department of Health and Human Services.

Utah is served by a federally facilitated exchange (FFE) in the individual market and operates a state-based exchange (SBE) serving small employers of 1 to 50 employees under the Small Business Health Options Program (SHOP) of the federal Patient Protection and Affordable Care Act. A notable component of Utah’s proposed Medicaid expansion program is those in the expansion population would receive federal Medicaid share funding to purchase commercial plans sold via the state’s small business exchange, Avenue H, and not the FFE, healthcare.gov. Those earning more than 100 percent of federal poverty levels (FPL) are eligible to purchase coverage in the FFE.

“Beginning in 2016, large businesses in Utah will likely face $11 to $17 million less in tax penalties each year if their employees making between 101 percent and 133 percent FPL are enrolled in a state-sponsored program rather than a Health Insurance Marketplace plan with a tax credit,” the document states. Employers of 50 or more full-time employees must offer health insurance to 95 percent of their workforces starting in 2016.

In addition, children who currently receive Medicaid would have the option to enroll in the same commercial plan their parents select through Avenue H. “Medicaid would continue to provide cost sharing and wrap-around coverage for these children to ensure they continue to receive the same level of coverage they do today,” the Healthy Utah plan states. “It is hoped that having a single primary health plan for the family will simplify coverage for the family. The federal government has previously denied Utah’s requests to use Medicaid funding to purchase these private plans. However, through the Healthy Utah negotiations, Utah was able to obtain approval for this type of assistance.”

 


Need a speaker or webinar presenter on the Affordable Care Act and the outlook for health care reform? Contact Pilot Healthcare Strategies Principal Fred Pilot by email fpilot@pilothealthstrategies.com or call 530-295-1473. 

Troubled launch of federal online exchange marketplace shows importance of IT project risk management

One of the essential elements of prudent project management is to have a plan to manage risks that can derail a project from getting done. Project managers everywhere are likely asking what kind of plan, if any, did the U.S. Department of Health and Human Services have in place to mitigate the risk of the online federal health insurance exchange marketplace that serves nearly three dozen states suffering a serious, systemic failure at launch. If the online marketplace simply bogged down due to heavy traffic during the first week after it opened for 2014 enrollment October 1, that would be a minor risk that could be mitigated by leasing more server capacity or simply by the passage of time as the initial rush died down.

According to today’s New York Times, however, the situation appears more serious than that. The Times quoted people working to get the online system functioning as saying it might not be ready by the December 15 deadline for individuals to enroll for coverage effective January 1, 2014. That would be a catastrophic start to the marketplace since the federal Affordable Care Act and conforming state laws contemplate the new individual health insurance market rules and exchange marketplace effective as of New Year’s Day.

Aware of the time pressure, the Obama administration is crashing the project, pouring in a team of IT experts to work 7/24 to get the online marketplace up and running properly. Many seasoned project managers would likely suspect that wasn’t in the risk management planning but is instead a last ditch response to a crisis.

One option that could have been in the risk management component of the project would have been a team developing a parallel system. If the site didn’t come up, IT staff could then switch over to the parallel site. Yes, it would cost more to have multiple development teams working in tandem. But given the novelty, complexity and high stakes of a functional online exchange marketplace project serving more than half the states, the higher costs would be justifiable.

If the crash fix doesn’t yield rapid relief as The Times story suggests, it’s possible administration officials have a contingency plan to effectively privatize the online federal exchange marketplace by outsourcing it to a commercial entity with experience running an online health insurance marketplace. If it did so, a possible candidate would be EHealth. The company, which operates the online insurance brokerage ehealthinsurance.com, was awarded a $19.3 million contract in July to help develop the federal online marketplace.

 


Need a speaker or webinar presenter on the Affordable Care Act and the outlook for health care reform? Contact Pilot Healthcare Strategies Principal Fred Pilot by email fpilot@pilothealthstrategies.com or call 530-295-1473. 

Multi-State plans roll out in 30 states, including some large ones and those operating state-based exchanges

The federal Office of Personnel Management (OPM) this week announced a pact with the Blue Cross and Blue Shield Association to offer more than 150 Multi-State Plan (MSP) options in 30 States and the District of Columbia on the Health Insurance Marketplace for plan year 2014.

Section 1334 of the Affordable Care Act creates a federally chartered (via OPM) Multi-State health plan (MSP) that must be offered in 60 percent of the state health benefit exchange marketplace in 2014 and all state exchanges by 2017. Section 1334 requires each state exchange to offer at least two MSPs (one must be a nonprofit) in their individual and small business exchanges. The policy intent is to bolster competition and consumer choice, particularly in states with smaller populations and fewer payers. The Affordable Care Act deems MSPs qualified health plans, according them presumptive eligibility for listing on state exchange marketplaces.

I expected to see MSPs first introduced in federally facilitated and partnership exchanges for 2014 and particularly in less populated states having fewer health plan issuers. Turns out the federal government decided otherwise, opting to initially roll out MSPs in some large states such as Pennsylvania, New York, Illinois and Texas as well as on state-based exchange marketplaces such as California, Maryland, Washington and Nevada. A staggering three dozen MSP options will be offered in Alaska.

 


Need a speaker or webinar presenter on the Affordable Care Act and the outlook for health care reform? Contact Pilot Healthcare Strategies Principal Fred Pilot by email fpilot@pilothealthstrategies.com or call 530-295-1473. 

Federal government forecasts “strong competition” in federally-facilitated state exchange marketplaces

A White House memo issued today reports the 19 states in which the federal Department of Health and Human Services will operate federally-facilitated health benefit exchange marketplaces will have “strong competition” among health plans when they open for enrollment in October.

Some data points from the memo:

  • A total of more than 120 health plan issuers have applied to offer qualified health plans in the HHS-run state exchange marketplaces.
  • Consumers will have multiple options in each actuarial value metal tier of coverage: catastrophic, bronze, silver, gold, and platinum.
  • On average, issuers plan to offer more than 15 qualified health plans per state, with some plans being offered in part rather than all of the state.
  • One out of every four insurance companies proposing to offer individual coverage has newly entered the market in HHS-run state exchange marketplaces.
  • About 65 percent of new issuer entrants to the individual market in the HHS-run state exchange marketplaces are in states where a single insurance company dominates the market.
  • The Office of Personnel Management is currently reviewing more than 200 proposed multi-state qualified health plan options.
 


Need a speaker or webinar presenter on the Affordable Care Act and the outlook for health care reform? Contact Pilot Healthcare Strategies Principal Fred Pilot by email fpilot@pilothealthstrategies.com or call 530-295-1473. 

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