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Focus on Regulation

CMS Seeks Comments on Qualified Health Plan Certification Requirements and Exchange Enrollment Forms

Following the Supreme Court’s June 28 decision regarding the Patient Protection and Affordable Care Act (PPACA), CMS has requested comments on the likely burden of the following four proposed data collection activities, each of which pertains to the health insurance exchanges to be established by 2014.  These data collection requirements are imposed on Exchanges, employees, employers, and individuals, respectively, and generally involve the use of CMS-created forms.

  1. Qualified Health Plan (QHP) Certification.  In order to offer health insurance through an exchange, a health plan must meet certain standards—including standards related to network adequacy, essential health benefits, and actuarial value–in order to be certified as a QHP.  Exchanges are responsible for collecting data to verify that plans meet the requirements of a QHP—a threshold requirement to being offered through an exchange.  CMS seeks comments on its initial guidance regarding this data collection requirement.
  2. SHOP Application Form for Employees. As required by Section 1311 of PPACA, CMS has developed a single, streamlined form that can be used by employees of small employers to enroll in QHPs offered in the small group market, as well as employees seeking coverage through a Small Business Health Option Program (SHOP) exchange.  CMS seeks comments with respect to this form.
  3. SHOP Application Form for Employers. Also, as required by Section 1311, CMS has created a single, streamlined form for small business employers who wish to provide coverage to their employees through a SHOP exchange. Employers will be required to provide the information in CMS’s form upon initial application to the SHOP exchange and at subsequent information collections. The proposed form would be required of all employers who wish to apply for coverage a SHOP exchange. CMS seeks comments with respect to this form.
  4. Enrollment Form for Exchange and Insurance Affordability Programs. As required by Section 1413 of PPACA, CMS has developed a single, streamlined form that states may use to have individuals apply for coverage through the Exchange and “Insurance Affordability Programs,” defined to include Medicaid, CHIP, the Basic Health Program, and federal premium and cost-sharing assistance.  States may opt to use their own form, as long as that form meets standards outlined by HHS. CMS seeks comments with respect to this form.