UCAOA Offers Comments on Proposals to Stabilize Insurance Market
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Even as the Republican plan to repeal Obamacare struggles to win support on Capitol Hill, including from moderate and conservative Republicans, the Administration is using its executive power and administrative authority to reshape the law.

In February, the Centers for Medicare and Medicaid Services (CMS) issued a rule that tightens special enrollment periods and defers to the states determinations of health plan network adequacy.  On March 7, the Urgent Care Association of America (UCAOA) responded to CMS’ proposals.  In its letter, UCAOA highlighted its principles for health reform and the role of urgent care centers in the delivery of health care.

On key proposals, UCAOA offered the following comments:

Guaranteed Availability:  As proposed, an issuer would not be considered as violating the guaranteed availability requirements if it requires a policyholder to pay all past due premiums owed to that issuer to resume coverage. In the event an issuer recoups premium non-payment, UCAOA believes the issuer should be required to pay claims submitted by the provider for that patient during the entire grace period.

Open Enrollment:  CMS is proposing a shortened consumer health plan enrollment period for 2018 (Nov. 1, 2017 to Dec. 15, 2017).  UCAOA supports a longer open enrollment period if the goal is to increase the number of Americans with health insurance.

Special Enrollment Periods:  Effective June 2017, CMS is proposing to conduct pre-enrollment verification of eligibility for Exchange coverage for all categories of special enrollment periods.  UCAOA asks CMS to abandon its proposal until it can be determined with some level of certainty that an eligibility verification process will not have a negative effect on risk pools.

Network Adequacy:  UCAOA believes network adequacy should be predicated on the network adequacy model act approved by the National Association of Insurance Commissioners. As proposed, CMS would eliminate a federal minimum threshold for adequacy and instead defer to the states reviews to ensure whether a “reasonable access standard” is met when assessing issuer network adequacy.

CMS must now issue a final rule, which may incorporate changes based upon public comment.

 

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