As we enter this new year, and our third year publishing and distributing Health Policy News, we want to thank you all for continuing to support Health Policy News as a source for in-depth policy and regulatory analysis.
The first few weeks of 2018 have been busy — with federal guidance released on association health plans as well as on Medicaid work and community engagement requirements, the approval of the first work requirement waiver in the country, and the passage of a bill to extend funding for the federal government, which included the long-awaited six-year renewal of federal funding for the Children’s Health Insurance Program (CHIP) as well as changes to taxes related to the Affordable Care Act (ACA). In this month’s edition, we explore these new developments in more detail and provide high level analysis of the potential impact of the recent guidance and statutory developments.
Also, as we mentioned in our 2017 Year in Review edition, we will be bringing readers more educational pieces on various topics throughout 2018. This month, we focus on Medicaid and Medicare fraud and abuse prevention, highlighting December 2017 guidance from the Government Accountability Office (GAO).
The final Notice of Benefit and Payment Parameter regulations and Letter to Issuers in the Federally-Facilitated Exchanges had not yet been released at the time of publication. Stay tuned as we look forward to distributing a summary and webinar invite shortly after the release.
As always, you can contact us at healthpolicynews@pcgus.com for more information on any of these pieces.
Administration releases the proposed rule on association health plans
On January 4, 2018, the administration released the anticipated proposed rule on association health plans, broadening the ERISA definition of “employer” and relaxing the requirements to be considered a group health plan for the purposes of expanding access to such plans. Association health plans are exempt from certain protections included in the ACA, including coverage of the ten essential health benefits.
The proposed rule seeks to redefine “employer” by creating a more flexible “commonality of interest” test. The “commonality of interest” test is currently defined as a “bona fide” group of employers with a common interest (other than obtaining health insurance) typically operating in the same industry, comprised of one or more employees other than the owner and owner spouse that exercise control over the association health plan (AHP)…Read More
CMS issues guidelines on mandating work and community engagement under Medicaid and approves the first work requirement waiver
On January 11, 2018, the Centers for Medicare and Medicaid Services (CMS) distributed a State Medicaid Director letter outlining new guidelines for states about mandating work and other community engagement activities for adult Medicaid beneficiaries who are not aged, disabled, or pregnant. Almost immediately following the issuance of the guidance, CMS approved Kentucky’s waiver, making them the first state in the nation with a work requirement waiver…Read More
Congress reauthorizes the Children’s Health Insurance Program
On January 22, 2018, Congress reauthorized funding for CHIP through Federal fiscal year (FFY) 2023. The CHIP provisions are included as the Healthy Kids Act under H.R. 195, Division C. Division B extends a short-term continuing resolution (CR), which was necessary to reverse a three-day federal government shut-down. Division D affects certain health care related taxes established under the ACA. The President signed the bill into law on January 22.
The Healthy Kids Act reauthorizes federal funding for CHIP covered health care services and administration, as well as special CHIP provisions such as…Read More
The Government Accountability Office issues recommendations on fraud prevention
n December 5, 2017, the GAO issued a a report on Centers for Medicare and Medicaid Services (CMS) fraud prevention efforts, recommending that CMS more closely align its approach with the Fraud Risk Framework put forth by the GAO in 2015.
Medicaid and Medicare fraud and abuse prevention has been increasingly in the spotlight as the federal government attempts to curb an increasing trend. In federal fiscal year 2016, improper payment estimates for these programs totaled about $95 billion. The GAO recommendations are likely to impact both CMS’s approach to fraud and abuse prevention as well as its expectations of states.
The GAO report credits CMS with anti-fraud efforts of the Center for Program Integrity (established in 2010) and CMS anti-fraud stakeholder training for providers, beneficiaries, and health insurance plans. However, the GAO points out that CMS has not conducted a fraud risk assessment for Medicare or Medicaid, nor has it designed or implemented a risk-based antifraud strategy. These approaches are crucial to the GAO’s Fraud Risk Framework, which draws on the…Read More
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