On April 6, 2017, Congress headed home for its spring recess having not achieved the Republican leadership’s goal of repealing, replacing, or repairing the Affordable Care Act. But even as these efforts go on, so does the life of the ACA.

On April 7, 2017, the Centers for Medicare and Medicaid Services (CMS) released the 2018 Unified Rate Review Instructions, which must be followed by insurers offering non-grandfathered health insurance coverage in single-risk-pool (individual and small-group) markets. The rate data filed by insurers are used by state and federal regulators to review rates and by CMS to calculate advance payments of premium tax credits and cost-sharing reduction payments.

All single-risk-pool plans in the individual and small group markets must file the Unified Rate Review Template (URRT). It applies to plans on and off the exchange including plans that experience no rate changes, rate decreases, and new plans, as well as plans that have rate increases. In addition, plans that have rate increases of 10 percent or more must file a consumer-friendly narrative justification of the rate increase.

An actuarial memorandum explaining the actuarial reasoning and assumptions, justifications, and methodologies for all rate increases in single-risk-pool plans must be filed whenever an insurer proposes any rate increase in a single-risk-pool plan or whenever a state regulator requires it. It is also required for all states in which the federal government reviews rates because the state does not have an effective rate review program, which for 2018 includes only Texas, Oklahoma, and Wyoming.

Rates are submitted on an annual basis for individual plans. Rates may be changed quarterly in the small group market, if permitted by state regulators, in which case the URRT must be submitted quarterly.

The 2018 rate review instructions contain a number of changes from earlier versions, most of which are very technical. For example, the URRT forms have been modified to accept two decimal index rate entries so that insurers can enter the rate to the nearest penny. Modifications have also been made to reflect changes in the 2018 Benefit and Payment Parameters rule. Several changes have also been made in an attempt to avoid common data entry user errors in earlier versions.

In a presentation of the new instructions at the National Association of Insurance Commissioners spring meeting, a CMS representative stated that CMS has a URRT 4.2 version ready to go that will accept the greater actuarial value variations that have been proposed in the market stabilization rule, and CMS will implement the new version instantly if the rule is finalized as proposed.

Redesigned QHP Website And New Insurer-State Communication Tool

On April 5, 2017, CMS also announced at its REGTAP.info website two new initiatives. First, CCIIO has redesigned the QHP (qualified health plan) website. The new website “features clear, easy-to-navigate headers,” “to better assist users in locating needed information and documentation.”

Second, CCIIO is launching for the plan year 2018 QHP certification period a pilot program using Salesforce to offer improved two-way communications between insurers and states. The program is called the “CCIIO Plan Management Community pilot.” State Departments of Insurance will be able to log in and access profiles for each insurer ID and plan ID in the state. State pilot participants will be able to

  • manage state contacts,
  • view issuer- and plan-level data for their state,
  • complete plan confirmation,
  • withdraw plans,
  • chat with CCIIO about non-policy issues, and
  • access QHP notices and updates from CCIIO.

States are asked to volunteer now to participate in Salesforce. They will receive training during April for a rollout of the program in May.