The Centers for Medicare and Medicaid Services (CMS) released a draft of its 2018 Letter to Issuers in the Federally-Facilitated Marketplaces (Letter) on November 10, 2016. The Letter – updated annually – provides operational and technical guidance for issuers seeking to offer Qualified Health Plans (QHPs) and Standalone Dental Plans (SADPs) on Federally-Facilitated Marketplaces (FFMs) and State-Based Marketplaces on the Federal Platform (SBM-FPs).
As with the Proposed Notice of Benefit and Payment Parameters for 2018 (NBPP for 2018), the Letter was released earlier than in prior years and on the heels of an election that raises significant questions regarding the future of the Marketplaces and the Affordable Care Act generally. However, until changes are made, issuers must begin working on plans for which they will seek certification to be included on the Marketplaces in 2018, which will have to be submitted this Spring.
PCG subject matter experts created a summary of the Letter that focuses on policy changes related to the QHP certification process from prior years’ Letters. Many of the changes outlined are more by way of clarification and providing greater detail rather than departures from prior policy. Most policy changes mirror changes proposed in the Notice of Benefit and Payment Parameters for 2018 or other guidance and are not new to this Letter.
Regulators across the country are reviewing these provisions to understand the changes and how they will impact their regulation of health plans and the markets in their states. To better support states as they analyze the impact of the proposed guidance for 2018, we welcome you to share the summary with colleagues, clients and others. PCG also hosted a webinar on the Letter on November 22nd. Please email RRiso@pcgus.com for a recording of the webinar.
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Published by Lisa Kaplan Howe
Lisa Kaplan Howe (J.D.) is a Senior Advisor who has spent her career working in health law and policy. At PCG, she focuses on statutory and regulatory analysis and strategic advising, particularly related to health care policy. Lisa has provided subject matter expertise to support state health care reform efforts, including policy development and regulatory support for health insurance Marketplaces and state insurance plan management efforts, Medicaid expansion and Medicaid Waivers (including DSRIP Waivers) and State Innovation Waivers. Lisa led PCG’s work with the New Hampshire Insurance Department relative the state’s Section 1115 Medicaid Waiver to provide coverage to newly-eligible adults through the Marketplace and continues to support the states’ Marketplace plan management work. In those roles, Lisa has served as the chief advisor and policy expert related to Medicaid and private insurance law to the New Hampshire Insurance Department, helping to identify, analyze and lead strategic consideration of federal opportunities and requirements. Lisa is also part of the team helping to design Colorado’s Delivery System Reform Incentive Payment (DSRIP) program. Ms. Kaplan Howe also provides broad policy and regulatory support to PCG’s other health care clients across the country, analyzing policy and regulatory developments, providing strategic advice relative to regulatory questions, and drafting policy briefs and position papers. Lisa is a managing editor of PCG’s monthly health practice area newsletter, Health Policy News.
Prior to joining PCG, Lisa served as Policy Director at New Hampshire Voices for Health, where she led legislative and regulatory analysis, strategic planning, and implementation of the organization’s policy agenda. Her work included drafting bills, amendments, testimony, and communications and testifying at hearings. Lisa also held the positions of Private Market Policy Manager and Consumer Health Policy Coordinator at Health Care for All of Massachusetts. While there, she managed private insurance market policy work and was a member of the organization’s internal health reform team. Lisa also practiced law in the Ropes & Gray health care department, advising health care provider and insurer clients.
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