As federal health reform legislation has stalled, health policy attention turns to the states, which have many tools to reform their health care systems. While 1115 waivers rightly get a lot of attention, because of their ability to reshape state Medicaid programs, the Affordable Care Act’s Section 1332 waivers continue to be a promising avenue for states.
Regulatory Analysis | Aug 11, 2011
HHS Proposed Rules on Exchange Implementation Requirements
Manatt Health Solutions – Deborah Bachrach, Patricia Boozang, Melinda Dutton and Alice Lam
Health insurance exchanges are the vehicle through which millions of Americans will gain access to coverage beginning in 2014. The U.S. Department of Health and Human Services (HHS) released its initial proposed rules on exchange implementation on July 11, 2011. This issue brief, authored by Manatt Health Solutions, highlights the provisions of the proposed rules that will impact state planning and implementation of exchanges. It summarizes they key provisions across a number of broad categories including exchange establishment, exchange functions, individual enrollment, the Small Business Health Options Program (SHOP), Qualified Health Plan (QHP) accreditation and certification, enrollment periods and effective dates in the individual market, and the exchange establishment process and criteria. The brief also identifies areas in the proposed rules that provide new insight on exchange development, for example the introduction of a new “state partnership model” for exchange development.