Today, the Connector Board met to discuss key issues the Connector must consider for implementation of the Affordable Care Act (ACA) – which programs, processes, and policies can they keep and which need to change? Materials from the meeting are here.
Executive Director Glen Shor framed this meeting as a “kick-off” of sorts, looking ahead to the 2014 Seal of Approval (SoA) process which needs to align with ACA-required Qualified Health Plan (QHP) certification. SoA set the standards carriers have to meet to sell plans through the Connector; QHP certification is a similar concept adopted in the ACA. Exchanges must be prepared to start selling QHPs by the federal open enrollment start date of October 1, 2013, for coverage effective January 1, 2014. Another major question is how the Commonwealth will reconcile federal Minimum Essential Coverage (MEC) with state Minimum Creditable Coverage (MCC), which are minimum coverage standards needed to meet the federal and state mandates, respectively.
Before the board jumped into the ACA conversation, Shor provided current program updates and perspective on the Connector’s successes in the past year. As of October 1, 2012, Commonwealth Care had 192,076 members and Commonwealth Choice had 43,346 members. Shor also referenced the Connector’s yearly progress report, which features feature stories of people who have benefitted from health reform – particularly from the Connector’s programs (this should be posted on their website soon).
The report also highlights the Connector’s work to become an ACA-compliant exchange. Shor said the Connector’s involvement in the Health Insurance Exchange/Integrated Eligibility System (HIX/IES) is a particular source of pride, as it will simplify the eligibility and enrollment process by linking state and federal databases and determining eligibility for subsidized coverage in real time.
Shor noted that in November and December, the Board will get into more substantive topics, including:
- Connector’s 2014 product shelf, standardized vs. non-standardized plans
- Employee choice model
- Stand-along dental plans
- Subsidized coverage and state supplemental subsidies for people between 200-300% FPL
- Wellness Track
2014 SoA & QHP Certification
Sarah Bushold and Jean Yang introduced the board to the concept of QHP certification in relation to the Connector’s current SoA process. Under the ACA, QHPs must meet “minimum certification standards” as defined by statute and regulations, but state exchanges have the flexibility to impose additional criteria. Bushold noted that the SoA model provides a robust foundation for QHP certification, and will be leveraged to ensure a smooth transition. The Connector will work closely with the Division of Insurance in developing QHP certification, which needs to be finished by October 1, 2013, which is the first day of open enrollment for coverage beginning January 1, 2014.
Nancy Turnbull asked whether the Connector would still be able to offer standardized benefits. Bushold and Shor responded that the Connector can require QHPs inside of the exchange to offer standardized products, but standardization would not reach all plans sold outside of the exchange (as happens now). Shor also noted that all products in the small group and individual market – both inside and outside the exchange – must fit into the federal metallic tiers (Platinum, Gold, Silver, Bronze), which are based on actuarial value.
MCC, MEC, and ACA Market Reforms
Kaitlyn Kenney gave an overview of key state and federal health insurance coverage standards and approaches to enforcing these standards. Massachusetts has about 30 state mandated benefits that all fully-insured plans must cover, and established Minimum Creditable Coverage (MCC) as the coverage standard used to satisfy the state individual mandate. While MCC designates certain types of coverage as per se compliant by statute, the Connector also promulgated regulations requiring certain services to be covered and setting out-of-pocket maximums.
The ACA, however, takes a different approach. Minimum Essential Coverage (MEC), the standard used to satisfy the federal individual mandate, simply identified broad categories of coverage that are “per se” compliant, such as all government, employer, individual, and grandfathered plans. Essentially, residents simply need to carry health insurance to meet the federal mandate.
However, the ACA also includes substantial insurance market reforms that apply to health plans differently. For example, only plans in the small and non-group fully insured market (both inside and outside the exchange) are required to cover Essential Health Benefits (EHBs). Massachusetts recently selected its EHB benchmark plan—Blue Cross Blue Shield of Massachusetts’ HMO Blue with pediatric dental services supplement from Harvard Pilgrim Health Care’s Best Buy HMO. Therefore, all small and non-group fully insured plans in Massachusetts will have to offer plans with benefits at least as robust as the HMO Blue plan. MEC and MCC reach all types of plans (albeit in different ways), and other types of market reforms (like limits on cost sharing) do not reach self-insured plans.
The key policy question for the Connector Board to consider is: Does there continue to be a role for the state’s MCC requirements to protect the quality of coverage people receive? This question prompted much discussion amongst the Board members. Some members felt that MCC continues to play an important role in health reform, while others opined that MCC may be out of date or unnecessary due to federal reforms. In the end, Board members requested that the Connector staff make recommendations on MCC and present it at a subsequent Connector Board meeting.
–Jessica Sanchez & Suzanne Curry