State Departments of Insurance Release Plans to Advance Access to Women’s Health Services 

The Centers for Medicare & Medicaid Services (CMS) followed-up on its Expanding Access to Women’s Health Grant Program awards this fall, sharing information about awardee state plans for funded initiatives.  CMS awarded nearly $9 million to support state department of insurance efforts to promote market reforms and consumer protections related to women’s health, with a specific focus on “state efforts to enhance and expand coverage of, and access to, reproductive health and maternal care.” The grant funds can be used for planning and implementation related to specific market reforms and consumer protections, including: 

• • • Reviewing and updating state Essential Health Benefit (EHB) benchmark plan selections; 
    • Collecting public input regarding the state EHB benchmark plan; 
    • Enhancing plan certification and market conduct review tools; and   
    • Outreach and education campaigns. 

Grants were awarded to fourteen states and the District of Columbia and range from $248,641 to $635,352. Below are examples of notable activities included across the state plans. 

Enhancing Coverage through Essential Health Benefit Standards and Standardized Plans

A number of the awardee states will perform actuarial analyses to assess opportunities to update the states’ current Essential Health Benefits (EHB) benchmark plan coverage of reproductive, maternal, and other women’s health services. Arkansas seeks to do a similar analysis with a focus on workforce – including midwives, doulas, and community health workers – and no-cost-share services. Massachusetts and Nebraska will look to other states and markets to identify innovative product designs. 

The District of Columbia seeks to enhance the coverage in its Exchange standardized plans, while both Colorado and Washington are seeking to promote the use of telehealth to provide maternal health services, especially in rural areas.  

• • • Take Note: States have broad flexibility to select an EHB benchmark plan to define the EHB coverage requirements that apply to plans in the state. That benchmark can now be based on a set of benefits selected by the state. States must notify CMS when it selects a new benchmark plan by the first Wednesday in May of the year two years prior to the effective date. Before doing so, states must provide “reasonable public notice” and opportunity for public comment on the plan selection. States with State-based Exchanges also have the ability to create state-specific standardized plans that carriers must offer on the Exchange. 

Strengthening Coverage through Enhanced Plan Reviews and Standard Processes 

Colorado plans to enhance their review of preventive services coverage in annual issuer filings to identify gaps in coverage and provider networks and inform enforcement actions. The Division of Insurance will use tools to automate data collection, review, and analysis. Washington will use the state’s All-Payer Claims Database to analysis access to and utilization of existing coverage, while Hawaii will focus on access to covered services, conducting a provider network adequacy analysis.  

Some states are focusing more on processes. New Jersey is updating standard policy forms to ensure appropriate coverage is provided, and Washington will implement standardized administrative processes for claims submissions and payment for certain reproductive and maternal healthcare services. Mississippi and Washington plan to conduct market conduct examinations to confirm insurers are delivering required preventive health services and following regulations. 

• • • Take Note: States conducting plan management functions as part of the Qualified Health Plan (QHP) certification review process have the opportunity to develop their own plan certification templates and tools for review of federal or state QHP standards – even states with Federally-facilitated Marketplaces (FFMs). And, of course, all states have the opportunity to integrate additional reviews into their state-based plan review and market conduct. Similarly, the use of standardized forms or processes is not new, with many states already having such requirements related to prior authorizations. 

Gathering On-the-Ground Input about Existing Coverage

Arkansas will gather qualitative and quantitative data through community-based focus groups, informational interviews with patients and providers, and partnerships with community health workers and local organizations to help identify gaps to inform policy changes and outreach activities. New Hampshire will similarly conduct surveys, interviews, and focus groups to assess women’s health knowledge and satisfaction. On the other hand, Nebraska will review consumer complaint and external review data to monitor for patterns of denials or access concerns, and Wisconsin will conduct data calls to assess compliance and identify practices that may create barriers to required coverage. 

• • • Take Note: Stakeholder input is critical to gathering data that can supplement findings from plan certification reviews, providing information about unintended barriers, and informing state policy and process decisions regarding opportunities to expand access to women’s health. These can and should take a variety of forms from online surveys to in-person forums, from focus groups and/or interviews to public stakeholder input sessions. In fact, states are finding that, through the use of skilled facilitators and proven facilitation methods, targeted stakeholder engagements can be used for a range of purposes, including to generate information, educate consumers and providers, and generate community-informed priorities. Many states also have multi-payer claims databases that can be leveraged for data. 

Launching Outreach and Education Campaigns to Improve Utilization

Mississippi will develop educational materials, seminars, and workshops related to women’s health, while the District of Columbia will enhance consumer understanding through consumer testing and research and New Hampshire will launch a social media campaign and women’s health dashboard. Maine will launch a targeted outreach and education campaign focusing on Black, Indigenous, People of Color (BIPOC) populations and low-income individuals. They will also convene workshops and expand outreach efforts related to reproductive and maternal health benefits.  

New Jersey plans to provide training for healthcare providers to better address the health needs of women and developing policy solutions to improve access 

• • • Take Note: Many states engaged in broad health insurance focused outreach and education campaigns to help residents learn about their state’s Health Insurance Marketplace, the coverage available to them, and to enroll in coverage. This included states with FFMs. Those campaigns – and proven best practices from them, including the use of social media campaigns, partnering with on-the-ground trusted organizations, and meeting people “where they are” in the community – can provide roadmaps to more targeted campaigns related to access to women’s healthcare.