Implementing Health Reform: Wraparound Coverage Excepted Benefits And Draft 2016 Letter To Issuers (Updated)
December 20th, 2014
In December 19, 2014, in what one hopes were their last major regulatory actions before the holidays, the Departments of Labor, Health and Human Services, and Treasury released a proposed rule on a new excepted benefit for wraparound coverage, while the Centers for Medicare and Medicaid Services released a Draft 2016 Letter to Issuers in the Federally Facilitated Marketplace.
This post will describe the wraparound coverage proposed rule. It will be updated in the next day or two to analyze the letter to issuers (issuers being the Affordable Care Act word for insurers.) I will note briefly, however, that the letter to issuers is very similar to the 2015 letter to issuers, with two major exceptions. First, because open enrollment for 2016 begins on October 1, rather than November 15, as in 2015, the time frame for completing regulatory review begins earlier and is quite compressed. Second, the 2016 letter picks up on a few new regulatory initiatives for 2016, such as attempts to provide more accurate provider directories and formulary information. These changes will be explored more thoroughly in the update to this post.Read the rest of this entry »