November 23rd, 2014
On November 21, 2014, the Centers on Medicare and Medicaid Services of the Department of Health and Human Services released its proposed Benefits and Payment Parameters (BPP) Rule. Part I of this post examined the benefit provisions of this proposed rule. This post will analyze the parts of the rule that deal with the insurance market reforms; the reinsurance, risk adjustment, and risk corridor programs; health insurance rate review; and the individual and SHOP exchanges.
New Definitions Of ‘Plan’ And ‘State’
The regulation begins with a modified definition of the term “plan.” The terms “plan” is important in the ACA regulations. A plan has been defined, with respect to a health insurer, as the combination of a benefit package, metal tier, and service area. The new definition adds to this combination cost-sharing structure and provider network, so that plans that differ in their cost-sharing structure (deductibles, copayments, or coinsurance) or provider networks are different plans, even if they are offered at the same metal tier. This definition becomes important, for example, in determining whether a plan offered outside the exchange is the same as a qualified health plan (QHP) offered in the exchange and can thus participate in the risk corridor program. The proposed regulations later propose that the unreasonable rate review regulation applies at the plan level.Read the rest of this entry »