Making Progress on Health Insurance Exchanges Without Definitive Guidance

Making Progress on Health Insurance Exchanges Without Definitive GuidancePosted by Kelly Sauders, Partner, Deloitte & Touche LLP

Health plans are waiting for CMS (The Centers for Medicare and Medicaid Services) to provide detailed requirements and guidance about participating in federal health insurance exchanges. In the meantime, we believe their leading bet is to refer to the managed care manuals for Medicare Part C and D. Or in the case of a state-run exchange, it probably makes sense to follow the state’s Medicaid guidelines.

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HIX Compliance for Health Plans

HIX Compliance for Health Plans

New structures come with new rules and health insurance exchanges (HIX) are no exception. That said, health insurers need to know more than the new rules — they need to understand the protocols and priorities regulators intend to use in building out this new regulatory regime.

This is a significant compliance challenge, but it does not begin with a blank page. Other government programs’ (Medicare and Medicaid) compliance capabilities that may already be in place serve as useful models for the analogous requirements of HIX participation. In fact, many of the exchange compliance priorities the Centers for Medicare and Medicaid Services (CMS) shared in March 2014 are similar to those used to regulate Medicare Advantage and Part D plans. Following that logic, it is likely that enforcement measures on HIX plans may mimic these other existing federally-funded programs.

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