March 12, 2014
On March 5, 2014, the Department of Health and Human Services (HHS) released its 2015 Notice of Benefit and Payment Parameters Final Rule. The Final Rule describes payment parameters applicable to the 2015 benefit year and standards relating to the:
Among other provisions, the Final Rule also implements patient safety standards for qualified health plans (QHPs) offered in the Health Insurance Marketplace (Marketplace) and includes standards related to the employee choice and premium aggregation provisions in federally-facilitated Small Business Health Options Programs (SHOPs).
Beginning in 2014, the Affordable Care Act (ACA) requires a three-year transitional reinsurance program to be established in each state. This program is intended to help stabilize premiums for coverage in the individual market during the first three years of Marketplace operation (2014 through 2016) when individuals with higher-cost medical needs gain insurance coverage. This program imposes a fee on health insurance issuers and self-insured group health plans.
Key highlights of the Final Rule with respect to the reinsurance program include the following:
The Final Rule finalizes the Marketplace's annual open enrollment period for the 2015 benefit year, which will begin on November 15, 2014, and extend through February 15, 2015. According to HHS, this schedule gives issuers additional time before they need to set their 2015 rates and submit their QHP applications, gives states and HHS more time to prepare for open enrollment, and gives consumers until February 15, 2015, to shop for coverage. The Final Rule does not change the schedule for the Marketplace's initial open enrollment period, which began on October 1, 2013, and goes until March 31, 2014.
Effective for plan years beginning on or after January 1, 2014, the ACA requires certain non-grandfathered health plans to comply with cost-sharing limits with respect to their coverage of essential health benefits. The cost-sharing limits include both an overall annual limit, or an out-of-pocket maximum, and an annual deductible limit.
The ACA requires that these limits be updated annually based on the percent increase in average premiums per person for health insurance coverage. The Final Rule establishes the cost-sharing limits for 2015, which are lower than the limits HHS originally proposed. For 2015:
The Final Rule is available at: http://federalregister.gov/a/2014-05052.pdf.
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This ACA Pathways is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice. The information contained in this ACA Pathways includes emerging health care news from a limited perspective and does not encompass all views. The information was selected from a wide range of sources selected on the basis of their potential impact on employers and/or their employee benefit plans. For more information, please contact Burnham Benefits.