With the enactment of health care reform legislation, the Academy has turned its attention to the regulatory phase. After a broad call for volunteers, the Health Practice Council has established a number of work groups charged with identifying areas in the law that need clarification through regulation, as well as developing comments on various provisions for submission to the Department of Health and Human Services, the National Association of Insurance Commissioners, and other relevant organizations. The work groups are separated into specific issue areas. These include:
Medical loss ratio reporting and rebates
Near-term benefit and eligibility changes (e.g., prohibition of lifetime benefits, extension of dependent coverage, and guaranteed issue for children)
Grandfathered plans
Creation of a premium review process
Establishment of a temporary high risk pool
Creation of a temporary reinsurance program for early retirees
Creation of a voluntary long-term care services program (the CLASS Act)
Regulatory Updates
The Department of Health and Human Services (HHS) solicited comments from the public on April 12 on Section 1003 of the Patient Protection and Affordable Care Act (P. L. 111-148), which requires the HHS secretary to work with states to establish an annual review of unreasonable rate increases, to monitor premium increases, and to award grants to states to carry out their rate review process. Comments should be submitted within 30 days of the April 14 Federal Register notice.
Also on April 12, the Internal Revenue Service (IRS), the Employee Benefits Security Administration (EBSA), and HHS issued a request for comments on medical loss ratios. Section 2718 of the Public Health Service Act requires health insurance issuers offering individual or group coverage to submit annual reports to the HHS secretary on the percentages of premiums that the coverage spends on reimbursement for clinical services and activities that improve health care quality. The law requires insurers to provide rebates to enrollees if this spending does not meet minimum standards for a given plan year. Comments should be submitted by May 14.
The Health Care Reform Solvency Impact Subgroup of the National Association of Insurance Commissioners' (NAIC) Financial Condition Committee held a conference call on April 15 to assess the concerns of health insurers, including the impact on solvency, as a result of the recently passed Patient Protection and Affordable Care Act. The NAIC subgroup addressed crafting definitions for the numerator and denominator for the medical loss ratio for HHS, establishing an emergency blanks proposal to collect specific health data from all health carriers based on common definitions and reporting breakouts, and aiding the NAIC's Accident and Health Working Group in establishing rate filing guidelines.
In the News
The Academy's Critical Issues in Health Reform paper on the Community Living Assistance Supports and Services (CLASS) Act was cited in an April 15 Kiplinger article. The Academy wrote that actuarially sound premiums for the new long-term care program could range from $125 to $160 per month. In addition, concerns raised by the Academy in a July 2009 letter regarding adverse selection issues that could threaten the CLASS Act's viability were cited in an April 1 Cincinnati Enquirer opinion piece.
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