Things should be starting up in the next few weeks for health plans interested in offering products in the FFE. Given the lack of specificity in the final exchange regulation and CMS’ pursuit of state help, potential applicants will be in a constant scramble to see who’s on first between the states and CMS. So, there is a need for tactical observation and quick analysis to determine their ability to meet each new twist as it is announced. It is a moving target of regulation that does not lead to a sense of certainty for any health plan that they can or will apply.
Preliminary CMS timelines call for submission of a notice of intent (NOI) to apply sometime in February. CMS relies on the NOI to begin to set up their automated systems for actual applications that will be received beginning in April. While CMS does not use the NOI to determine their need for resources, a large response could do just that. Also, the NOI is not binding, starting with a fairly incomplete set of requirements means that applicants can only estimate their willingness to follow through with an application and merely send one in to check the startup box in the process.
CMS has also let it be known that there is no timeline for states to decide if they want to be a regulator in the FFE. Some state legislators in FFE states are being pressed for more state regulatory action by their constituent health plans. So, it is likely that some health plans will not know which regulations will be applied as they make a decision to complete the application.
No doubt, CMS is looking for the lowest common denominator that will relieve their worry over resources as well as the concerns of potential applicants. However, potential applicants need to know ASAP if the FFE requires building new structures and operations or not when state rules are determined sufficient. While submitting an NOI is a no-brainer, the expense of actually making the application under these uncertain circumstances has real budgetary meaning for some health plans and may staunch some of the willingness to complete the application.
The preliminary FFE timeline looks like this.
February – March
- Health Plans submit Notice of Intent to apply
- FFE Health Plan Application released
April – May -
- CMS begins review of applications
- CMS releases benefit module
- CMS tests consumer application
June – July – CMS Call Center goes live
- CMS conducts all application reviews
- CMS reviews all benefit proposals
August – September
- CMS completes all health plan FFE agreements
- CMS readies each FFE for enrollment operations
- Open Enrollment begins
November – December
- Open Enrollment continues
- Open Enrollment continues
- QHPs begin coverage period for enrollees
- Open Enrollment Ends
Download Jean LeMasurier’s whitepaper on Insurance Exchanges in the ACA.
Read Gorman Health Group Chairman, John Gorman’s, blog titled “Exchange Activity Kicks into High Gear“.