The Health Connector Board met today to discuss the Connector’s Commonwealth Care oversight initiative, Appeals Unit update, and the public education and strategic outreach an advertising procurement. Materials from the meeting are here, and our full report is after the break.
Commonwealth Care Oversight Initiative
Stephanie Chrobak (Director of Operations), Jean Yang (Chief Financial Officer), and Daniel Apicella (Manager of Healthcare Finance) provided an update on the Connector’s CommCare performance analysis and oversight initiative. The purpose of the initiative is to evaluate CommCare’s performance in access, quality and cost efficiency, in light of FY12 program changes.
- Flat enrollment since September 2011: Current enrollment is 158,801.
- MCO membership changes reflect FY12 program changes (i.e. limited choice for some incoming Plan Type I members): Network Health and CeltiCare gained members while BMC HealthNet, Neighborhood Health Plan, and Fallon Community Health Plan lost members.
- Incoming Plan Type I members between June-November 2011: 70% of Plan Type I members with limited choice chose Network Health and 30% chose CeltiCare. Of those Plan Type I members with unlimited choice, 46% chose BMC HealthNet and 42% chose Neighborhood Health Plan.
Provider Network Capacity
- As of November 2011, about 47% of CommCare members are covered under a low-cost, narrower network MCO – Network Health or CeltiCare.
- Significant variations among MCOs in the number of acute care hospitals and primary care physicians; smaller variability in community health centers.
- Since April 2011, both Network Health and CeltiCare have expanded their hospital networks.
- All hospitals and community health centers throughout the state are contracted with at least one MCO.
- Transfer Activity: With the exception of Plan Type I members with limited choice, all incoming CommCare members can transfer plans within the first 60 days of enrollment. In addition, members who experience a qualifying event can change plans. Outside of open enrollment, there are about 361 transfers a month, or about 0.26% of the CommCare population.
- Premium Hardship Waivers: 0.25% of CommCare premium payers filed a hardship waiver thus far in FY12; a majority of these waivers have been approved.
- Disenrollment and default transfer due to premium non-payment: In early FY11, there was a spike in Plan Type 2A transfers for premium non-payment, due to the decrease of health plans with no premium from three to one. There has been an uptick in disenrollments for premium non-payment at the beginning of FY12.
- Premium collection: There has been a slightly lower collection rate so far in FY12, which is to be expected at the beginning of a fiscal year.
Program Call Center Performance
- Customer service performance remains steady: Average length of call, wait time, and abandonment rates are below industry standards.
- Outreach & Education: The Connector created tutorials on an overview of CommCare, web registration, 1099 HC forms, and open enrollment. Next up: tutorial on making online premium payments.
- Member web utilization: Web usage continues to increase for CommCare members. As of October 2011, the Health Information Portal can be accessed using all internet browsers. This is good news for Mac users who previously had trouble accessing the portal.
- Program Integrity: The Connector continues to utilize services from Health Management Systems (HMS) and data matches with federal and state agencies to make sure CommCare serves the intended population, that is, people with access to other insurance are not enrolled in CommCare.
Secretary Jay Gonzalez stated that it is interesting to call Network Health and CeltiCare narrow networks while naming BMC HealthNet a broad network. Jean Yang responded that just because a plan has a broad network doesn’t mean it has 100% of the providers in its network. Gonzalez reflected that none of the CommCare MCOs are broad in the broadest sense, particularly by region. That is, any CommCare member in any plan does not have complete choice of where they go. He stated that Network Health still has broad choice even though it has narrowed its network.
Nancy Turnbull said that almost every part of the state has a dominant health system, and it is interesting to think about whether we define limited networks as those that do not include the dominant health system in the region. Celia Wcislo expressed concern that there are not enough open primary care physician panels to meet the need of the increasing number of people who are enrolling in Network Health and CeltiCare. Glen Shor responded that plans tend to change their networks to address changing needs over time. The Connector plans to look at patient access more thoroughly through a member survey and utilization data analysis.
Connector Appeals Unit Update
Ed DeAngelo (General Counsel) provided the Board with an update on the Connector’s appeal and certification processes with regards to the individual mandate, minimum creditable coverage (MCC) and CommCare eligibility and premiums.
Individual Mandate Appeals
Taxpayers can appeal an individual mandate penalty on the grounds of hardship. In 2007 and 2009, the majority of appellants were not penalized. There was a jump in appeals and penalties in tax year 2008, which was the first year penalties were assessed on a month-to-month basis. Individual mandate appeals for tax year 2010 should wrap up by the end of this month.
Beginning in tax year 2009, the mandate required individuals to obtain insurance that meets Minimum Creditable Coverage (MCC). That year, approximately 375 taxpayers claimed a hardship related to non-MCC compliant coverage. However, with the way the data is currently collected, the Connector is unable to parse out non-compliance with the mandate due to being uninsured versus holding a non-MCC compliant health insurance plan.
Certificates of Exemption allow taxpayers to apply for exemption from individual mandate penalties in advance. Applications are due by December 1st of each year, and the same hardship criteria as an individual mandate appeal apply.
The Connector worked with the Department of Revenue to produce a more detailed report on individual mandate data in tax year 2009.
Minimum Creditable Coverage Certifications
Health insurance carriers can self-assess that their plans meet MCC standards, or they can seek certification from the Connector on whether the plan is actuarially equivalent to a Commonwealth Choice Bronze plan. Licensed Massachusetts carriers are required to disclose to consumers whether their plans meet MCC.
The most common deviations from MCC include deductibles, ER copays that do not count towards the deductible, and out-of-pocket maximums. Most plans that apply for certification are approved.
Commonwealth Care Appeals
Individuals can appeal CommCare eligibility determinations, disenrollment, denials of premium or copay waivers, and denials of health plan transfer requests. Most CommCare appeals are eligibility related. As of November 30th, the Connector received 4,204 CommCare appeals in 2011. 1892 of these appeals were dismissed; of the 1892 dismissed appeals, 809 were resolved as CommCare or MassHealth eligible.
Public Education, Strategic Outreach and Advertising Procurement
Before requesting a vote to enter into a contract with Weber Shandwick, Richard Powers (Director of Communications) gave a brief overview of the Connector’s past and future strategic communications efforts. Following passage of Chapter 58 in 2006, the Connector contracted with Weber Shandwick in to run a public education, outreach, and advertising campaign focused on getting individuals enrolled in Connector programs. Moving forward, the Connector’s communications strategy will focus on Business Express.
The Board discussed about how to reach the remaining uninsured Massachusetts residents, most of whom are below 150% of the federal poverty level and are likely eligible for MassHealth or CommCare. Several board members cited the importance of working with community organizations.
The Board voted unanimously for the Connector to enter into a contract with Weber Shandwick effective January 1, 2012 through June 30, 2013.
The next Connector Board meeting is scheduled for Thursday, January 12th from 9:00-11:00am at One Ashburton Place, 21st floor, Boston.