The Academy's Premium Review Work Group submitted comments on Feb. 22 to the Department of Health and Human Services (HHS) on proposed regulations to implement the rate increase disclosure and review provisions under the Affordable Care Act. The work group responded to several specific requests for comments in the proposed regulations, including whether 10 percent is a reasonable threshold to apply in determining the increases subject to review, and the additional factors that should be considered when determining whether a rate is unreasonable.
The Academy's Medical Loss Ratio (MLR) Work Groupcommented on Jan. 31 to HHS on the interim final regulations implementing the MLR requirements under the Affordable Care Act. The comments addressed technical aspects of the interim final regulations to improve clarity and internal consistency, including the definition of "multi-state blended rate," the measurement date for earned premiums, the definition of paid claims included in incurred claims, the data used in multi-year calculations, and the calculation of the deductible factor for policies with dependents.
Legislative and Regulatory Updates
The HHS on Feb. 2 issued a request for comments on proposed new regulations establishing the Consumer Operated and Oriented Plan Program (CO-OP) of the Affordable Care Act. The CO-OP program would identify "qualified nonprofit health insurance issuers" that offer qualified health plans in the individual and small group markets. The secretary of HHS would provide loans to assist in funding start-up costs for these issuers and award grants to assist them in meeting state solvency requirements. Comments are due March 4.
Proposed regulations that would establish rules for student health insurance coverage under the Public Health Service Act and under the Affordable Care Act were issued by the HHS on Feb.11. Comments on the proposed rules, which would define student health insurance coverage as a type of individual health insurance coverage, are due April 12.
In The News/Media Activities
A widely published Op-Ed that was included in the Deseret News (Salt Lake City) on Jan. 29 quotes the Academy from the Health Practice Council's January 2010 letter to congressional leaders on health care reform. Regarding the Community Living Assistance Services and Supports (CLASS) Act, the Academy wrote that "given the way the program is structured, severe adverse selection would result in very high premiums that are likely to be unaffordable for much of the intended population, threatening the viability of the program." The Academy's adverse selection concerns with the CLASS Act also were captured in a National Journal feature that appeared online on Feb. 17 and in print on Feb. 19, which included comments from Academy volunteer and long-term care expert Steve Schoonveld, and a New York Times article that appeared online on Feb. 21 and in print on Feb. 22. Schoonveld discussed the adverse selection concerns in more detail in a Feb. 24 Reuters piece, which also linked to the Academy's CLASS Act FAQ. He also discussed the average costs for various long-term care services in a Feb. 8 Time column.
The Academy's Medicare Reform Optionsmonograph was cited on Jan. 30 in a Citizen of Laconia article that covered Rep. Frank Guinta's (R-N.H.) visit with state representatives and local media. During his visit, Guinta discussed a "defined contribution" approach to reforming Medicare. The monograph was used to help elaborate on the concept.
An Op-Ed published in the Pittsburgh Tribune-Review on Jan. 30 referred to the Academy Consumer-Driven Health Plan (CDHP) Work Group's analysis of CDHP research studies. The work group found that high-deductible plans reduce costs between 12 and 20 percent in the first year and between 3 and 5 percent annually in subsequent years.
The New York Times quoted Academy Health Practice Council Vice President Tom Wildsmith on lifetime limits in an article that appeared online on Feb. 1 and in print on Feb. 2. Wildsmith said that the cost of eliminating lifetime limits on health coverage, as prescribed by the health care reform law, is very modest.
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