The Center for Medicare and Medicaid Services (CMS) released their final rules for next year’s open enrollment last week. There are a couple of big rules that will have significant impact.
Default Enrollment Options
A QHP that was certified in 2014 and that is recertified in 2015 can maintain the same plan and HIOS identification numbers that it used in 2014. Additionally, current enrollees in recertified plans will remain enrolled into the new benefit year, as long as those enrollees do not terminate their coverage.
The assumption will be that a person who is enrolled in good standing in a plan that is offered in both 2014 and 2015 will be re-enrolled in that plan for the 2015 plan year. This, I think, is a good rule. I have talked a couple of times about choice overload and this should reduce choice overload a bit where the default is opt-out of renewing instead of opt-in to renew. The big problem will be for individuals who are in bad plans this year who want to change, the default will discourage a few people from changing to better plans. The experience with Medicare Part D shows that the improvement of choice is a multi-year process.
For benefit year 2015, we will utilize a general ECP enforcement guideline whereby if an application demonstrates that at least 30 percent of available ECPs in each plan’s service area participate in the provider network, we will consider the issuer to have satisfied the regulatory standard. In addition, and as required for the prior year, we expect that the issuer offer contracts in good faith
Essential Community Providers (ECP) are core community services (AIDS, hemophilia, birth control, federally qualified health clinics, community health clinics etc). In 2014, a plan only had to contract with 20% of the ECPs in a region. Now it is 30% or a damn good explanation. The narrowest networks will become a little bit wider. This may not change the decision to include high end specialty hospitals like Seattle Children into a network but it should improve access in non-urban center counties for the narrowest networks. Modestly narrow networks probably won’t be changed by this rule.
Open Enrollment will be November 15, 2014 to February 15, 2015. Enrollment in a policy on or before Dec. 15 will have coverage effective date of Jan. 1, enrollment between 12/16 and 1/15 will have coverage effective on 2/1/15 and enrollment between 1/16 and 2/15 will have effective coverage on 3/1/15. Final plan design approval will occur by October 15, 2014, so there will be a month long advertising blitz as plans are approved.
There are plenty of other details that interest me (and should interest anyone invested in coffee futures), but these are boring technical implementation details.