Health Policy News – January 2019


As readers are likely aware, the Centers for Medicare and Medicaid Services’ (CMS) long-awaited annual Exchange guidance was released on January 17, 2019, and, as in past years, PCG subject matter experts have prepared a summary of notable changes to assist states in parsing through this voluminous guidance. In addition to the summary, PCG will also host a webinar on Thursday, February 7th at 2:30pm EST. We hope you will join us for the webinar and bring questions related to the Proposed Notice of Benefit and Payment Parameters for 2020 and the 2020 Draft Letter to Issuers in the Federally-facilitated Exchanges.

Review of Proposed 2020 QHP Guidance – Proposed Notice of Benefit and Payment Parameters & Draft Letter to Issuers

Thursday, February 7, 2019

2:30 pm | Eastern Daylight Time (New York, GMT-04:00) | 1 hr

Meeting number (access code): 793 806 488

Meeting password: 2020QHPguidance

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Although our main focus this month is the Exchange guidance summary, we also are providing an update on Medicaid buy-in programs, including highlights from the New Mexico report released last month, and a reminder from PCG’s Cost Allocation team on how to correctly cite the consolidated and streamlined guidance know as the Uniform Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance).

As always, please be in touch with any questions related to this content. We look forward to speaking with you on Feb 7th during our webinar.

CMS releases its long-awaited Exchange guidance for 2020

The Centers for Medicare & Medicaid Services (CMS) released first drafts of its long-awaited annual Exchange guidance on January 17, 2019, including the Proposed Notice of Benefit and Payment Parameters for 2020 (NBPP) and the 2020 Draft Letter to Issuers in the Federally-facilitated Exchanges (Letter). As always, the NBPP and Letter set forth changes to rules and operational and technical guidance for health plan regulation, Exchange operations (including plan certification and financial parameters), and premium stabilization programs for the 2020 plan year.

In an effort to support states as they seek to understand the impact of the changes proposed in the NBPP and Letter for 2020 on their regulation of health plans and the markets in their states, PCG subject matter experts created a summary of notable changes. Click here for more information on the proposed guidance and a link to the summary.

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Update on Medicaid Buy-In Efforts: Public Impressions and Specific Approaches to Medicaid Buy-in Programs

Many states considering a Medicaid buy-in public option have expressed the hope that it will provide an affordable coverage option for individuals, noting that insurance remains highly costly even for those individuals receiving Federal premium subsidies or employer contributions. This month we provide insights into public impressions of the range of buy in options available to states, as well as details of a how a state might structure such a program—with New Mexico releasing Phase 1 of their study in December 2018. Click here for more insights into recent developments and what’s to come on this topic.

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A Reminder from PCG’s Cost Allocation Team to Reference the Correct Federal Guidance in Cost Allocation Plans and Indirect Cost Rates

December marked five years since the Federal Office of Management and Budget (OMB) consolidated eight prior OMB Circulars into a single source of Federal guidance, and four years since that guidance went into effect. Many Federal agencies also adopted the Uniform Guidance into their own regulations, including the Federal Department of Health and Human Services, which adopted the Uniform Guidance in 45 CFR Part 74.

The Uniform Guidance contains changes that impact cost allocation and audit requirements. For example, changes to standards of documentation requirements to support payroll charges to Federal grants and raising the threshold for the Single Audit to $750,000.

Yet, despite all the years, we still see Federal, State, and other agencies referencing the former OMB Circulars—such as OMB A-87 and OMB A-133—rather than the consolidated and streamlined guidance.

For more information about the consolidated guidance and why referencing it matters, click here for insights from PCG’s Cost Allocation team.

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