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ADAP Preparation for the 2018 Plan Year June 28, 2017
ADAP Preparation for the 2018 Plan Year
June 28, 2017
Overview of Presentation
1. What’s New for 2018: Overview of Market Stabilization Rule and Federal Updates
2. Review of Insurance Purchasing Cost-Effectiveness Requirements and NASTAD Plan Assessment Tool
3. ADAP Strategies to Ensure a Smooth Open Enrollment
4. New Resource: In the Loop
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What’s New for 2018: Overview of Market
Stabilization Rule and Federal Updates
What’s New: OE5 DatesShortened Open Enrollment for 2018 Plan Year
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November 1, 2017Open Enrollment Start
December 15, 2017End of Open Enrollment
Last Day to Enroll to Effectuate January 1 Coverage
January 1, 20182018 Plan Year
Coverage Begins
ADAP Consideration: Plans are allowed to accept premium payment up to 30 days from date of enrollment; many require it on or before coverage begins
ADAP consideration: Plan information should become available a little before November 1; states should check in with departments of insurance for plan information as well
Medicaid enrollment is continuous throughout the year
What’s New: Special Enrollment PeriodsMarket Stabilization Rule Makes the Following Changes to Special Enrollment Periods (SEPs) for All States that Use Healthcare.gov
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SEP Change SEPs Affected Implementation Date
Pre-enrollment verification Starts with most common SEPs: loss of minimum essential coverage, permanent move, Medicaid/CHIP denial, marriage, and adoption
First phase begins June 2017 (for loss of coverage and permanent move); other SEPs listed begin in August
Demonstration of one day of prior coverage in previous 60 days
Marriage and permanent move June 2017
Plan selection restrictions for individuals already enrolled in a QHP (must stay within same metal level)
All June 2017
Exceptional circumstances SEPs will be limited
Exceptional circumstances SEP June 2017
What’s New: Payment of Past Due Premiums
▪ Consumers who owe premiums may not be allowed to enroll in coverage in any product offered by that issuer until the premiums are paid
o This does not apply to products sold by other issuers, only products sold by the issuer to whom the individual owes past due premiums
o Issuers do not have to apply this policy if they choose not to
o Issuers may accept installment payments or set a threshold of payments they will accept
o Issuers must provide written policy on treatment of past due premiums
Bottom line: Case managers and assisters should work with clients to determine if there are past due premiums and either work with the plan on a payment plan or choose a different issuer
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What’s New: Higher Consumer Cost Sharing
▪ The Market Stabilization Rule gives plans more leeway to meet the ACA’s actuarial value standards – allowing issuers to sell slightly less generous plans with higher consumer cost-sharing than they had been allowed to offer under previous rules
▪ The changes do not apply to cost-sharing reduction silver level plans
▪ Bottom line: it will be important to assess which plans will provide the best coverage for ADAP clients, with close attention to out-of-pocket costs
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What’s New: Network Adequacy
▪ For the 2018 plan year, states will have greater responsibility for monitoring compliance with federal network adequacy requirements
▪ For the 2018 plan year, the Essential Community Provider standard (which includes Ryan White Program providers) will be reduced; meaning that plans are obligated to contract with fewer ECPs
▪ Bottom line: it will be important to monitor provider networks to ensure access to HIV and Ryan White providers
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Congressional Activity▪ The Senate is in the process of developing ACA
repeal and replace legislation (similar to the House-passed American Health Care Act)
▪ Whether the bill can garner 50 votes are not clear
▪ IF a bill were to pass Congress:o Impact would not be immediate; phase outs would exist
for changes to subsidies to purchase private insurance and Medicaid
▪ Bottom line: The ACA and insurance protections are still the law of the land and clients should continue to enroll in coverage
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Review of Insurance Purchasing Cost-Effectiveness
Requirements and NASTAD Plan Assessment Tool
Insurance Cost-Effectiveness
▪ Insurance cost-effectiveness is assessed at the aggregate program level, not the individual plan levelo Is the average cost per client for all insured clients lower
than the average cost per client of all full pay clients?
▪ Less expensive insured clients (Medicare Part D, younger clients with lower premiums) can offset higher expenditures for other insured clients
Insurance Cost-Effectiveness (ctd.)
▪ Consider the net costs of both insurance and drug purchase, inclusive of discounts and rebateso If you include discounts in your drug cost estimate, need
to include rebates in your insurance cost estimate
▪ Rule of thumb – if anticipated rebates exceed the cost of the insurance, plan is clearly cost-effectiveo These rebates can offset higher-cost planso Do not prohibit higher-cost plans without looking at total
program costs in the aggregate
▪ ADAP Cost-Effectiveness tool estimates rebates relative to the premium and cost-sharing payments
NASTAD Plan Assessment Tool
NASTAD Plan Assessment Tool
NASTAD Plan Assessment Tool
NASTAD Plan Assessment Tool
▪ NASTAD will release a revised version of the Plan Assessment Tool in fall 2017 in anticipation of the next open enrollment period
▪ Please contact Amanda Bowes with any questions:o [email protected]
o (202) 434.8095
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ADAP Strategies to Ensure a Smooth Open Enrollment
1) Start Preparing Enrollment Workforce
▪ Identify Navigators, Certified Application Counselors, and other assisters in your jurisdiction and make sure they are aware of ADAP role
▪ Consider partnering with an agent or broker
▪ Encourage case managers and enrollment staff to work with clients well ahead of open enrollment to update their healthcare.gov accounts
▪ Ensure that clients who received APTCs have filed their federal taxes
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2) Develop Strategy for Plan Assessment
▪ Consider contracting with a third-party to do a plan assessment for ADAP once plan information becomes available
▪ Assess all plan options, including off-Marketplace plans
▪ Familiarize yourself with NASTAD’s tool: NASTAD is here to help!
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3) Stay Calm
▪ Address client and case manager concerns and questions early and often
▪ Start planning ahead of November 1
▪ Engage department of insurance and enrollment partners
▪ Let NASTAD know how we can help!
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