This blog was originally posted on Say Ahhhh! A Children’s Health Policy Blog.
Hard to believe it’s come around again but that National Associatin of Insurance Commissioners (NAIC) is gearing up for a big national meeting – this time in Orlando, Florida from October 18-21. I and my fellow consumer representatives will be packing our Mickey Mouse ears and fanning out at the big regulator-industry confab to share our views on how to make the Affordable Care Act implementation work for consumers and families. The NAIC has a lot of work packed into just a few days. Here’s a preview of what they’ll be doing and how it might impact children and families:
* Helping states implement the September 23 patient protections. NAIC’s “Regulatory Framework Task Force”, chaired by South Dakota’s Director of Insurance, Merle Scheiber, has been drafting model laws to help states implement many of the “Patients’ Bill of Rights” protections in the ACA, such as the prohibition on pre-existing condition exclusions for children under 19, required coverage for young adults up to age 26, preventive benefits, restrictions on annual limits and the ban on lifetime limits, internal and external appeals, and the prohibition on rescissions. The Task Force has almost completed its efforts, and is expected to take up final edits and changes during its meeting in Orlando on October 18. State advocates can expect that many states will use these models to craft the necessary legislation to enforce these new consumer protections. We’ll also be talking to the regulators about strategies to keep child-only plans in the market and make kids’ coverage more affordable.
* Developing an Exchange model law. The NAIC has created a new workgroup, co-chaired by Commissioner McRaith from Illinois and Commissioner Praeger from Kansas, to develop a model law for states to establish an insurance exchange. This group will be meeting on October 20th to review the draft model law and discuss possible recommendations to HHS on issues like governance, exchange functions, network adequacy, marketing standards and quality ratings. During their summer meeting in Seattle, the workgroup also agreed to create a high-level liaison group to state Medicaid directors, led by Commissioner Praeger. We’ll be eager to hear about that group’s efforts to date, particularly on how they intend to address the “no wrong door” goals of the ACA and coordination of care for low-income families that may be cycling between Medicaid and commercial insurance.
* Medical Loss Ratios. NAIC’s draft regulation to define the medical loss ratio (MLR) under the ACA was posted on October 5. It’s likely to be voted on by NAIC’s Excecutive Committee and Plenary during their final meeting in Orlando on October 21st. We’re expecting some fireworks as the insurance industry pushes back hard against some of the tougher requirements. In particular, insurance agents are asking that they be left out of the equation. The bottom line for families purchasing insurance: the MLR standard is a measure of how much a health plan devotes to actual medical care as opposed to overhead and profits. We’ll be urging the NAIC to stay strong against industry pressure to weaken the standard.
* Consumer Information. One of the most important yet least publicized consumer protections in the ACA is the requirement for more transparency in the information provided to consumers about health plan benefits, exclusions, premiums and cost-sharing. NAIC has been charged with developing the standardized definitions and summary of benefits form that all qualified health plans must provide to consumers making purchasing decisions. The NAIC’s Consumer Information workgroup, co-chaired by Superintendant Kofman from Maine and Commissioner Miller from Oregon, has been working diligently all summer on the summary form and is now awaiting the results of focus group testing. Once the focus group results are back, the group will meet in Orlando to finalize the summary of benefits form. HHS will likely then include it in a regulation expected in March of 2011. The consumer reps on this group are working hard to make sure that consumers get the information they need to make purchasing decisions that are right for their situation, without having to worry about hidden contract language that leaves them financially vulnerable when they need care.
The NAIC meetings are open to registered participants, but the travel, hotel and fees are a significant expense. Advocates for children and families are welcome to contact any of the NAIC’s consumer reps to ask questions or share any comments.
— Sabrina Corlette, Georgetown Health Policy Institute