Note: This blog was updated to reflect new information from the Centers for Meidcare and Medicaid Services (CMS).
More than 11 million people have signed up for 2015 coverage during the second open enrollment period. This enrollment success is in large part thanks to all of the assisters and advocates who used highly effective outreach strategies to enroll people across the country. You are all deserving of a much-needed break, but, as usual, there is more work to be done! While you are still helping consumers enroll and learn how to use their 2015 coverage, insurers are putting together applications for 2016 qualified health plan (QHP) certification.
A tight timeline
According to CMS’ letter to insurers, insurers participating in Federally Facilitated Marketplaces (FFMs) must submit a completed QHP application for all plans they intend to offer on an FFM by May 15. These applications will include a package of plans and benefits, rates data and provider networks. The review and revision phase will last through September 14. In general, state departments of insurance will play a significant role in reviewing these plans for compliance with market-wide requirements. However, for certain areas, such as network adequacy, CMS will keep a close watch on insurers’ compliance. If a QHP application is approved, insurers will receive the certification notices and sign the contract agreement to get ready for the third open enrollment period. These key dates are for insurers participating in FFMs, but State Based Marketplaces (SBMs) are advised to follow the same timeline.
Now is the time to affect requirements for 2016 plans
Community Catalyst developed a one-pager outlining the timeline and some action steps to assist you in your work as you advocate to strengthen consumer protections and work to ensure a positive consumer experience in shopping for coverage, accessing care and improving health outcomes. To get you started, we recommend three buckets of work for the next few months:
- Network adequacy that enables consumers to access needed care for covered benefits in a timely manner
- Rate review that guarantees opportunities for consumer engagement
- Benefit design that includes the selection of essential and non-discriminatory health benefits
The specific issues within each bucket will depend heavily on your state environment and resources. However, you can start your work by capturing consumer stories to highlight successes or identify areas of improvements, barriers to care and emerging coverage issues at the state and federal level. These consumer stories will help you make the case for strengthened consumer protections with policymakers and stakeholders. Of course these three buckets of work are just the tip of the iceberg! If you or any of your state partners would like to share your strategies on the issue areas identified above, or others, please leave a message in the comment box.