2021 Plan Certification Standards and Regulation Update
This update outlines the proposed changes and approved standards for the 2021 Plan Certification in healthcare. It includes policy concepts, background information, proposed changes, and no proposed changes. The focus is on improving affordability, enhancing consumer access, and increasing enrollment rates in the marketplace.
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2021 Plan Certification Standards and Regulation Update Johanna Fabian-Marks, Director of Policy and Plan Management January 21, 2020
2021 Plan Certification Standards
2021 Plan Certification Standards & Policy Concepts 2021 Plan Certification Standards & Policy Concepts seek to: 1. Build off improvements in 2020. 2. Establish reasonable consumer expectations for out-of-pocket costs. 3. Align consumer incentives for health care service utilization. 4. Increase enrollee effectuation rates in the individual marketplace. 5. Increase access to stand-alone dental coverage through Maryland Health Connection. 3
Background Proposed 2021 Plan Certification Standards were presented to the Board at the September 2019 meeting. The Board approved final 2021 Certification Standards at the October meeting. Following an additional opportunity for comment on the draft 2021 Letter to Issuers, we recommend one change to the 2021 Certification Standards. 4
2021 Plan Certification Standards: Proposed Change Standard: SHOP issuers shall offer at least one QHP at the bronze, silver, and gold metal levels that allows for Composite Rating for employers seeking to offer a single plan to their employees. Goal: Expand access to alternative premium options for small employers participating on the SHOP. Feedback: Insurers shared additional questions and concerns related to implementation and the related administrative burden. Proposal: Given the efforts planned for this year to improve affordability in the small business market, and to make it easier for small business to shop for plans, we propose removing this from the 2021 plan certification standards and revisiting this as a potential 2022 standard. Allows MHBE time to further discuss this proposal with small businesses and insurers, and to hear more from small business regarding what they would consider most helpful in increasing the number of small businesses that offer health insurance to their employees. 5
2021 Plan Certification Standards: No Proposed Changes We do not propose changes to the other 2021 Plan Certification Standards approved by the Board. Value Plans: Limited modifications to the Value Silver Plans: modified before deductible services to include Generic Drugs and exclude Imaging. PayNow URL Requirement: Within calendar year 2021, issuers participating on Maryland Health Connection shall implement a PayNow URL to allow consumers to pay their first month s premium at the point of enrollment. MHBE shall provide flexibility to issuers contingent upon technological/timeline limitations. Co-pay Accumulator Program Transparency: Issuers shall disclose in their Important Information About This Plan document if they utilize a Co-pay Accumulator Program for prescription drugs covered in their formulary and provide information on how the program may impact out-of-pocket costs. Expand Access to Stand-Alone Dental Coverage: Stand-Alone Dental Plans shall accept enrollments under special enrollment periods for coverage offered on Maryland Health Connection upon: determination of eligibility for Medical Assistance Programs or a Qualified Health Plan, new enrollment in the Small Business Health Options Program, and access to an excepted benefits HRA. Lower Administrative Barriers for New Market Entrants: Offer optional sample plan designs at the bronze, silver, and gold metal levels. 6
Board Action Required Staff requests that the Board approve the removal of the 2021 plan certification standard that SHOP issuers shall offer at least one QHP at the bronze, silver, and gold metal levels that allows for Composite Rating for employers seeking to offer a single plan to their employees from the 2021 Plan Certification Standards and issuer letter. 7
Consumer Assistance Regulation Amendments Amendments make minor changes to 14.35.02, .03, .04, .05, .08, .09, .12, and .13 These regulations concern consumer assistance worker groups The amendments: o Remove existing reinstatement provisions because there was no functional difference between an initial application and an application for reinstatement, and o Clarify training requirements Proposed regulations were presented to the Board at the September meeting. Comment period closed November 25, 2019 o MHBE received no comments o No changes were made 9
Board Action Required Staff requests that the Board approve the adoption of the proposed regulation amendments to 14.35.02, .03, .04, .05, .08, .09, .12, and .13, as published in Volume 46, Issue 22 of the Maryland Register dated October 25, 2019, and to submit a Notice of Final Action for publication in the Maryland Register. 10
Thank you! @MarylandConnect
Appendix: Additional Information on 2021 Plan Certification Standards
2021 Value Plan Certification Standards YEAR 2021: No changes for the Value Bronze or Gold Plans. Limited modifications to the Value Silver Plans. Requirements Minimum offering Bronze Silver Gold Issuer must offer at least 1 Value plan. Required. No requirement. Lower deductibles are encouraged. Issuer may allocate no less than three office visits across the following settings: Issuer must offer at least 1 Value plan. Required. $1000 or less. Issuer must offer at least 1 Value plan. Required. $2500 or less. Branding Medical Deductible Ceiling Services Before Deductible Primary Care Visit Urgent Care Visit Generic Drugs Specialist Care Visit Laboratory Tests*+ X-rays and Diagnostics*+ Primary Care Visit Urgent Care Visit Generic Drugs Specialist Care Visit Laboratory Tests* X-rays and Diagnostics* Primary Care Visit Urgent Care Visit Specialist Visit Recommended to maintain, or decrease, cost sharing from 2020. *May be subject to limitation. +May be excluded from before deductible services. 13
2021 Value Plan Certification Standards YEAR 2021: No changes for the Value Bronze Plan. Limited modifications to the Value Silver and Value Gold Plans. Both Value Silver and Value Gold Plans: No change in deductible ceiling. Value Silver only: o Modified before deductible services to include Generic Drugs. o Modified before deductible services to exclude Imaging. Value Gold only: o Flexibility Options to help issuers meet Value Gold requirements offsets to increases in AV may, but are not limited to, include: 1. 2. 3. Changes in cost sharing for Specialist Care Visit, Laboratory Services, X-rays and Diagnostics, and Imaging. Limitations for Laboratory Services, X-rays and Diagnostics, and Imaging. Exclusion of Imaging from Before Deductible Services. Flexibility Issuers have the flexibility to modify plan design within the Value Plan requirements. MHBE shall provide additional flexibility to issuers contingent upon limitations that may arise with the release of the 2021 Actuarial Value Calculator. 14
PayNow URL Requirement STANDARD: Within calendar year 2021, issuers participating on Maryland Health Connection shall implement a PayNow URL to allow consumers to pay their first month s premium at the point of enrollment. MHBE shall provide additional flexibility to issuers contingent upon technological/timeline limitations should they arise. GOAL: Increase coverage effectuation in the individual market. 1. Promote market stability through increased member months. 2. Lowers the administrative barriers to access coverage for consumers. EXTERNALITIES: 1. When coupled with other enrollment initiatives (the Maryland Easy Enrollment Health Insurance Program) this requirement may increase coverage up-take for target populations. 2. Creates a uniform customer service experience on Maryland Health Connection. UTILIZATION: The PayNow URL was utilized 11,000+ in Open Enrollment 2018. 15
Co-pay Accumulator Program Transparency STANDARD: Issuers shall disclose in their Important Information About This Plan document if they utilize a Co-pay Accumulator Program for prescription drugs covered in their formulary and provide information on how the program may impact their out-of-pocket costs. GOAL: Increase coverage transparency for enrollees with who utilize coupons to reduce the cost their prescription drug. 16
Expand Access to Stand-Alone Dental Coverage STANDARD: Stand-Alone Dental Plans shall accept enrollments under special enrollment periods for coverage offered on Maryland Health Connection for the following trigger events: 1. Determination of eligibility for Medical Assistance Programs. 2. Determination of eligibility for a Qualified Health Plan. 3. New enrollment in the Small Business Health Options Program. 4. Access to an excepted benefits HRA. GOAL: Expand access to dental coverage and increase enrollment in Stand-Alone Dental Plans offered on Maryland Health Connection. 17
Lower Administrative Barriers for New Market Entrants STANDARD: Offer optional sample plan designs at the bronze, silver, and gold metal levels. GOAL: Lower administrative barriers for potential new market entrants with limited experience with plan design development. 18
