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On a Roll – Rules to Implement Health Reform Issued Fast and Furiously

The health reform mandates keep rolling along.

On September 23, 2011, many plans are required to implement a second increase in their annual limits to $1.25 million per person, per policy year for non-grandfathered individual, small group and all large group plans. A year ago, the Patient Protection and Affordable Care Act (PPACA) eliminated lifetime limits and began phasing out annual limits over the next several years.

But plans must tackle a much bigger administrative burden come early next year. On the second anniversary of PPACA, plans must implement federally mandated Summary of Benefit rules for grandfather and non-grandfather plans.

Advocates believe this is a consumer friendly move meant to standardize and simplify how benefits are presented to beneficiaries in summary documents. They believe this will allow consumers the ability to compare and contrast plans from different insurers to understand the best coverage option and estimate out-of-pocket cost. For many insurers and plans this will mean a wholesale overhaul of their benefit documents shortly after significant changes to include other new mandates and benefits in policies that have just taken effect.

The new summary of benefits will have to be sent out to members beginning for new coverage and renewal coverage effective on or after March 23, 2012. Also, plans are obliged to send out a new summary to those who request one and if plans change benefits during the year (although a modified document can also be sent in this case).

To meet the federal and state renewal timeframes, plans will need to have final documents ready in very early 2012. The final rule may not be issued until late 2011, but HHS has largely followed the recommendations of the National Association of Insurance Commissioners (NAIC).

In the past month, HHS and the other federal implementing entities have issued numerous proposed rules for health reform, including setting standards for state exchanges, and detailing the temporary reinsurance and risk corridor programs and the permanent risk equalization programs. Other rules have been issued that outline eligibility for exchanges and Medicaid and SCHIP expansions, and eligibility for health reform’s various tax credits. More on this over the next several weeks.

Marc Ryan

Marc S. Ryan serves as MedHOK’s Chief Strategy and Compliance Officer. During his career, Marc has served a number of health plans in executive-level regulatory, compliance, business development, and operations roles. He has launched and operated plans with Medicare, Medicaid, Commercial and Exchange lines of business. Marc was the Secretary of Policy and Management and State Budget Director of Connecticut, where he oversaw all aspects of state budgeting and management. In this role, Marc created the state’s Medicaid and SCHIP managed care programs and oversaw its state employee and retiree health plans. He also created the state’s long-term care continuum program. Marc was nominated by then HHS Secretary Tommy Thompson to serve on a panel of state program experts to advise CMS on aspects of Medicare Part D implementation. He also was nominated by Florida’s Medicaid Secretary to serve on the state’s Medicaid Reform advisory panel.

Marc graduated cum laude from the Edmund A. Walsh School of Foreign Service at Georgetown University with a Bachelor of Science in Foreign Service. He received a Master of Public Administration, specializing in local government management and managed healthcare, from the University of New Haven. He was inducted into Sigma Beta Delta, a national honor society for business, management, and administration.

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