Connector Board Approves Non-Standardized CommChoice Plans and Looks Ahead to ACA Implementation

Today, the Connector Board met to consider offering non-standardized plans in Commonwealth Choice and discuss the Connector’s Affordable Care Act (ACA) implementation work.  Materials from the meeting are posted here.

Executive Director’s Report

Glen Shor, the Connector’s Executive Director, reported enrollment numbers as of September 1, 2012: 

Commonwealth Care (CommCare):  192,322, compared to 189,354 as of August 1st.

Certain documented immigrants (referred to as Aliens with Special Status, or “AWSS”) who recently re-gained eligibility for CommCare increased from 25,247 to 26,860 of the CommCare membership, while new non-AWSS members grew by 1,355.  The Connector is analyzing reasons for the increase in non-AWSS membership, which the Connector expects is due to transitions from the Medical Security Program upon termination of unemployment insurance and eligibility redetermination schedules.

 Commonwealth Choice (CommChoice): 42,396, compared to 39,623 as of August 1st.

This represents a 7% increase, with 2,380 new non-group members.  The Connector is conducting more analysis on non-group enrollment, and will get more information out to the Board and public soon.

Shor announced that Dick Powers, the Connector’s Communications Director since its inception in 2006, is retiring at the beginning of October.  Health Care For All sincerely thanks Dick Powers for his role in health reform’s success, particularly his ability to convey stories of Massachusetts residents who have been helped through reform.  We hope Dick thoroughly enjoys his retirement – he deserves it.

CommChoice 2013 Seal of Approval

Sarah Stephany (Plan Management Coordinator) and Jean Yang (Chief Financial Officer) shared the results of the Connector’s 2013 CommChoice Seal of Approval process.

Under the current CommChoice contract, which ends December 31, 2012, carriers must:

  • Sell products in all CommChoice programs;
  • Offer plans in all six benefits packages under three tiers (Gold, Silver, Bronze);
  • Offer plans that meet the Connector’s standardized benefit design (i.e. benefits and cost-sharing); and
  • Offer products on their broadest commercial network.

The above components allow consumers to easily make apples-to-apples comparisons between plans.  However, with implementation of the Affordable Care Act (ACA), the Connector aims to retain current members and attract new members in the small and non-group market by increasing market appeal, while maintaining a balance between standardization and choice.  Hence, the Connector proposed adding a few non-standardized plans to the CommChoice “shelf” beginning January 1, 2013.

In 2013, all carriers must continue to offer standardized products in all benefit tiers, which all 8 existing CommChoice carriers and new entrant Network Health have agreed to.  However, carriers will have the ability to provide approved non-standardized plan options in addition to the standardized options.  Fallon Community Health Plan proposed to offer each of its five standardized Silver and Bronze plans on an additional provider network, Steward Community Care Network as well as two non-standardized plans.  Harvard Pilgrim proposed one non-standardized plan and Health New England and Neighborhood Health Plan proposed two non-standardized plans each on their broadest commercial networks.  As a result, the Connector received a total of 22 new products.

The slides presented by Connector staff lay out how the non-standardized plans differ from standardized plans, including actuarial value comparisons and cost-sharing differences.  Using the actuarial values, the Connector arranged the non-standardized plans into the corresponding standardized tier (Bronze, Silver, or Gold).

In an effort to maintain a transparent and simplified shopping experience while integrating these new products, the Connector will add an “Other” category to the CommChoice website with details of non-standardized plans in each corresponding metal tier.  The Connector is also designing decision support tools to allow consumers to narrow plan options by provider, annual deductible, and/or cost-sharing design (i.e., whether a plan has co-insurance).  Dolores Mitchell suggested clearly stating on the website that under the Affordable Care Act (ACA), cost-sharing does not apply to preventive services.

Several board members expressed concern on the move to offering non-standardized plans.  Jon Gruber suggested that the Connector should recognize the variations within the “Other” category, and that decision support tools are important so people know what they are buying and what their financial responsibilities are.

Nancy Turnbull said that the Connector should be mindful of whether the products they are offering are actually the most popular, as two of the largest carriers in the state did not propose to offer a non-standardized pan in 2013.  Celia Wcislo suggested that the Connector analyze all CommChoice plans and see how many people are in each plan.  If enrollment in a certain plan is very low, the Connector should consider removing it from CommChoice.  Mitchell commented that just because a certain plan is popular does not mean it is a good plan; the Connector must continue to ensure that people are not underinsured.

Wcislo said that many people do not understand co-insurance until they get a bill, partially because the state did not have many plans with co-insurance until a few years ago.  Turnbull agreed, and added that with co-insurance the consumer does not know the cost of the service, what the insurer will pay, and what their responsibility will be for covering that cost, whereas deductibles cap out at a certain amount.  Chapter 224, the recently signed payment reform law, seeks to address this issue of cost transparency.

Gruber argued that deductibles are akin to 100% co-insurance with an out-of-pocket maximum, and the uncertainty around cost of services is not unique to co-insurance – it applies to deductibles as well.  Shor clarified that from the Connector’s experience, people often ask whether a plan has co-insurance, and thus the Connector included this separate filter in their decision-making support tools.

The board unanimously voted to award the 2013 Seal of Approval to all carriers and products recommended by the Connector.

National Health Reform Update

Camie Berardi, Senior Policy Analyst, and Daniel Apicella, Senior Manager, Finance, provided an overview of the Affordable Care Act (ACA) Exchange approval process and federal funding opportunities.

ACA regulations require the federal Department of Health and Human Services (HHS) to approve a state’s Exchange by January 1, 2013.  States have the option of selecting a state-based, state partnership, or federally-facilitated Exchange.  To receive approval, a state must submit a declaration letter selecting an Exchange model and a completed Blueprint Application that documents how the Exchange meets or will meet all legal and operational requirements.  Clearly, Massachusetts has opted to continue running its state-based Exchange, the Connector.

The Blueprint Application lists 124 distinct activities that a state-based Exchange must perform.  While the ACA’s Exchanges are modeled on Massachusetts’ Connector, there are several areas in which the Connector must enhance policies and operations.  Among the Connector’s new responsibilities are: creating and funding a navigator program, determining real-time eligibility for advanced premium tax credits (i.e. subsidies) to purchase insurance through the Connector and work in tandem with MassHealth to connect people with coverage programs outside the Exchange, and implementing a risk adjustment program for the entire small and non-group market.

The Connector has already secured federal funding to support ACA implementation work:

  • Exchange Planning Grant: Analysis of major policy decisions and evaluation of infrastructure.
  • Early Innovator Grant: ACA-compliant IT design and implementation.
  • Level 1 Establishment Grant: Reinsurance, risk adjustment and risk corridor research and planning; Exchange revenue and cost model development; state operating model development for the Connector and MassHealth; Qualified Health Plan (QHP) product strategy, project management support, and outreach and education grants.

In August, the Connector submitted another Level 1 Establishment Grant application to fund additional projects to support the transition to an ACA-compliant Exchange, and expect to hear a response from HHS in late September or early October.  The Connector can apply for a Level 2 Establishment Grant as early as November 2012.

The next Connector Board meeting is scheduled for Thursday, October 11th from 9:00-11:00am at One Ashburton Place, 21st floor.

-Suzanne Curry

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