The U.S. Department of Health and Human Services has officially invited health insurers and dental insurers to apply for slots on the 2016 HHS exchange system plan menus.
The Center for Consumer Information & Insurance Oversight — the arm of HHS in charge of day-to-day exchange system operations — put the call for qualified health plan and stand-alone dental plan applications in a formal letter to issuers.
The letter applies only to slots at the HHS-run exchanges, not the state-run exchanges. The QHP and dental plan approval timeline shows that:
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Initial applications for 2016 HHS exchange menu slots will come in from April 15 through May 15.
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Exchange program managers will review the applications and ask for corrections and additional information by June 30.
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Insurers will get the corrected applications to reviewers by July 10.
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The reviewers can ask for a second round of corrections. Insurers will file the final versions of the applications by Aug. 25.
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Reviewers will send plan certification notices and plan agreements by Sept. 18.
The third annual open enrollment period is set to run from Nov. 1, 2015, through Jan. 31, 2016.
CCIIO sent out similar issuer letters for the 2014 and 2015 PPACA exchange plan enrollment periods. The new letter is the official version of a draft that came out in December.
In addition to outlining the plan approval timeline, the new letter includes information about many other 2016 HHS exchange procedures and requirements.
Officials note, for example, that the HHS-run exchanges will continue to offer dental plans in 2016 but will not offer slots for other types of plans, such as stand-alone vision plans, disability insurance plans or life insurance policies.
Officials also talk about rate review procedures and benefits design standards.
Over the past year, critics have suggested that insurers may have held down QHP enrollment by people with health problems by imposing high cost-sharing requirements on users of certain types of drugs, or by setting age limits on access to types of care that might be useful to patients of all ages.
"For example," officials write, "it might be arbitrary to limit a hearing aid to enrollees who are 6 years of age and younger, since there may be some older enrollees for whom a hearing aid is medically necessary."
Similarly, if a would-be QHP issuer refuses to cover a single-tablet version of a drug that's just as effective as a multi-tablet version, "such a plan design might effectively discriminate against, or discourage enrollment by, individuals who would benefit from such innovative therapeutic options," officials say.
Putting most or all drugs that treat a specific condition on the highest cost cost-sharing tier is another plan design strategy that may amount to discrimination against patients with that condition, officials say.
CMS will encourage regulators in states that are helping to enforce PPACA to discourage plan design-based discrimination, and CMS will look for signs of discrimination by analyzing appeals and complaints, officials say.
CMS may conduct a review to see if some QHPs impose unusually high out-of-pocket costs for patients with conditions such as bipolar disorder, diabetes, HIV, rheumatoid arthritis and schizophrenia, officials say.
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Allison Bell
Allison Bell, a senior reporter at ThinkAdvisor and BenefitsPRO, previously was an associate editor at National Underwriter Life & Health. She has a bachelor's degree in economics from Washington University in St. Louis and a master's degree in journalism from the Medill School of Journalism at Northwestern University. She can be reached through X at @Think_Allison.
