Overview and Analysis of Proposed Exchange, Medicaid and IRS Regulations Issued on August 12, 2011
Manatt Health Solutions
On August 12, 2011, the U.S. Department of Health and Human Services issued two sets of proposed rules focus on Medicaid and Children’s Health Insurance Program (CHIP) eligibility and enrollment procedures, as well as eligibility for exchanges, insurance affordability programs and Qualified Health Plans. The same day, the Internal Revenue Service released a proposed rule providing guidance on determining eligibility for and calculating the amount of premium tax credits offered through the exchange. This report, prepared by Manatt Health Solutions, analyzes those three federal draft regulations that, taken together, offer new insight into how consumers and employees of small businesses will obtain health insurance across the continuum of coverage options proposed in the Affordable Care Act. The regulations provide operational level details that can: inform state planning efforts; guide the design and implementation of business processes, IT and administrative systems; and, ultimately, impact consumer experience with state-based exchanges and Medicaid.