Exchange Operations Regs Due Next

Recently at a Bipartisan Policy Center forum, CMS said the health insurance exchange regulations from HHS will cover enrollment and eligibility requirements. As we saw firsthand with the messy launch of Medicare Part D in 2006 — one plagued by enrollment and eligibility SNAFUs for the first 6 months of the program, which kept thousands of beneficiaries from their needed medications — the guidance can’t come soon enough to ensure states and health plans have sufficient time and resources to get ready.

CMS said the forthcoming rule has a number of guiding principles:

• While it will be difficult given the intricacies of coordinating dozens of databases of healthcare consumer eligibility information, HHS is committed to flexibility for the states in figuring it out.  The ACA requires the exchange to be a one-stop shop for determining eligibility in either the exchange, Medicaid, the Children’s Health Insurance Program, or employer subsidies.
• There are wildly different eligibility rules for Medicaid, CHIP and the exchange subsidies, so streamlining those rules and procedures — such as for income verification — is key.
• ACA put emphasis on a simple enrollment process, for a simple reason: the vast majority of US citizens have never actually bought health insurance on their own.  Most is provided through your employer, with the help of a friendly local broker.  Exchanges need to be able to take a relatively small amount information from a consumer and be able to determine their eligibility for a range of healthcare subsidies, in near-real time.  Simple for the consumer — a monster for states and health plans to figure out.  This is building the healthcare equivalent of Orbitz or Travelocity from a green field, to be presented to consumers who for the most part will have no idea what they’re doing.

CMS said the eligibility and enrollment guidance will be coming “soon” but as is customary, wouldn’t specify, though the draft reg has been submitted to OMB for approval, which means we can expect it in the next 60-90 days.  And once that happens, the sluggish exchange planning process occurring in the states will get shot out of a cannon.