In late August, the Centers for Medicare and Medicaid Services (CMS) issued its Notice of Benefit and Payment Parameters for 2018. This is a proposed rule issued annually by CMS to create and update policies on a wide range of individual and small group market issues. With this current proposal, CMS aims to strengthen the risk pool, increase enrollment, and promote innovation in the marketplaces.
Here is a sampling of the proposals that CMS is seeking feedback on from the outreach and enrollment community:
- Risk adjustment: Modify the risk adjustment program for issuers to account for partial-year enrollees, prescription drug utilization, and other changes to better balance risk across issuers and create more stability in the marketplaces.
- User fee and outreach funding levels: Maintain user fees at 3.5 percent of premiums in 2018. CMS is also specifically seeking comments on how much of the user fee should be devoted to outreach and education efforts. Currently, CMS devotes 15 percent of these user fees to the functions of marketing, outreach, and plan management. (See pages 16-18 in Enroll America’s comments on the 2017 Payment Notice to read about the critical need to robustly fund outreach and education efforts in order to maximize enrollment.)
- Standardized plan offerings: In addition to updating the standardized plan for 2018 based on the most popular offerings in 2016, CMS is adding a high-deductible option for all marketplaces. They’re also adding a couple of alternate options that can be offered in place of the standardized plans for issuers in states that have requirements that conflict with the standardized plan (e.g. a state law that requires physical therapy cost-sharing to not exceed the cost of a primary care visit).
- Special Enrollment Period (SEP) policies: Codify several existing SEPs (including for dependents of American Indians, victims of domestic abuse, etc.) as well as seeking input on how to encourage eligible individuals to enroll and prevent ineligible individuals from enrolling with an SEP.
- Direct enrollment by issuers or web brokers: Adjust current policies surrounding direct enrollment including allowing issuers and web brokers to provide a more streamlined enrollment experience (instead of redirecting to HealthCare.gov for parts of the process) and adding consumer protections around items like plan and information display, tax credits, and third-party audits.
For those interested in weighing in on these policies, comments are due October 6.