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C.L. "BUTCH" OTTER
DEPARTMENT OF INSURANCE
700 West State Street, 3rd Floor
P.O. Box 83720
Boise, Idaho 83720-0043
WILLIAM W. DEAL
Idaho Carrier Questions and Answers, Part 1– May 3, 2013
The following questions have been received by the Idaho Department of Insurance regarding the Idaho Health Insurance Exchange and SHOP (Idaho Exchange), the filing process, Qualified Health Plan standards, and other related topics. The answers are intended to offer guidance on current issues based on the DOI’s current understanding. If you have any concerns regarding the accuracy of any of the guidance, please contact Wes Trexler at the DOI by phone or email at 208‐334‐4315 or firstname.lastname@example.org. The DOI will continue to release additional information and revise these responses as needed.
- What is the Idaho exchange user fee?
A. (Revised 8/8/2013) The Idaho Health Insurance Exchange Board set the 2014 fee during the June 28, 2013 board meeting at 1.5% of premium.
- What fee should carriers use in QHP filings prior to the Idaho Exchange Board setting
the exchange user fee?
A. For filings made prior to the board’s decision, carriers should use what they reasonably expect for the exchange user fee. Once the fee is determined, and if different than that contained in the filing, the DOI will submit an objection to the filed exchange fee through SERFF, allowing carriers the opportunity to modify the templates and documents as needed to reflect only the change to the fee. If for whatever reason, modifications are not sufficient, the DOI will allow new filings after May 31, 2013 for the narrow purpose of fixing the exchange fee used in the rate development. Changes to the Unified Rate Review Template (URRT) or the actuarial memorandum will also need to be resubmitted through HIOS. Please be aware that all objections will need to be resolved with sufficient time for the DOI to complete its review and certification of QHPs by the DOI’s July 31, 2013 deadline.
- What are the names of the rating areas so that we can input them in our rating
template? The bulletin identifies how the areas are defined but will there be a standard
naming convention that will be used by all the carriers?
A. Please see http://cciio.cms.gov/programs/marketreforms/id‐gra.html for the standard naming convention of the Idaho geographic rating areas. Subject to revision
- What is the minimum number of medical plans that a carrier may offer through the
A. A carrier must at a minimum offer a silver and gold plan in each market in which the carrier wishes to participate. Variant plans are required under Federal law for the Cost‐ Sharing Reductions for the Silver metal level and the two Indian variant plans for all metal levels.
- Will the Notice of the Ten (10)‐Day Right to Examine a Policy requirement be applicable
to the QHPs?
A. Idaho Code and Rule 30 provisions will be applicable unless preempted by federal law. The notice of the ten‐day right to examine a policy is not considered preempted.
- Must the SERFF filing of the policies, Outlines of Coverage (OOCs) and/or Summaries of
Benefits and Coverage (SBCs) be “filed” before we can associate the filings in the binder
or can the policies just be in submitted and in the review at the DOI process when we
create the binder?
A. The SERFF process involves first filing the materials and then associating the filings to the binder. The materials do not have to be accepted as filed prior to being associated with a binder. Additionally, all materials are not required to be filed simultaneously.
- Will the DOI be using the FFE standards to determine network adequacy?
A. We plan on using network adequacy standards similar to the FFE standards.
- If the state has a question regarding a deficiency, will this be handled like an objection
A. Yes, that is the current expectation. SERFF filing guidelines and procedures for QHP binders are the same as all other filings.
- We have been advised in CCIIO meetings the Medical Loss Ratio & Uniform Rate Review
Template (URRT) will need to be sent to HIOS as well as SERFF. Are you aware of
additional templates that will also need to be submitted to SERFF?
A. The URRT and the actuarial memorandum must be filed with HIOS at the same time as the filing with SERFF.
- Rate filings must be filed through SERFF by May 31. What is the timeline for forms such
as our contracts or certificates?
A. The May 31, 2013 “soft” filing deadline in the March 26, 2013 Notice to Carriers applies to contracts and certificates, as they are part of a complete SERFF binder filing.
- Have you established a filing deadline for non‐exchange products?
A. Non‐exchange QHPs should also be filed by May 31, 2013. There is no established deadline for non‐QHPs. However, please be aware that the single risk pool standard requires that all plan rates be based on the same URRT.
- For Individual, will there be opportunities to change rates after they are filed? Once we
have submitted our products and rates, can we drop them? What is the cutoff date?
A. Rates, forms, and templates can be modified through May 31, 2013. After that date, modifications that are not made at the request of the DOI may result in the modified plan/product being moved in priority behind non‐modified plans/products. Carriers can withdraw QHP applications through July 31, 2013.
- For Small Employer, the ACA and regulation (45 CFR § 155.705(b)(6)(i)) allows for
rates to be changed on a quarterly, monthly, or annual basis. What will the filing
timeline be for quarterly changes?
A. Regarding the 2014 calendar year, the DOI recommends that carriers file quarterly trend adjustments with the initial submission, including each set of quarterly rates on separate sheets of the Rate Template. At this time, it is unclear if the Idaho SHOP will be prepared to accept additional adjustments to rates effective during the 2014 calendar year, beyond expected quarterly trend.
- Do rate manuals need to be included with the QHP filings?
A. Idaho Code requires a rate manual be filed with the DOI prior to use. The DOI will consider a complete QHP filing, which includes all requested templates, to have met this requirement.
- Regarding the SHOP in Idaho, is the DOI going to limit options?
A. The DOI does not plan to limit options on the SHOP, outside of the finite departmental resources explained in the March 26, 2013 Notice to Carriers.
- Will there be specific questions that we should ask prospective members?
A. Yes. Please see the federal application for preliminary guidance. The Idaho Exchange Board may decide to provide additional guidance with the Exchange application.
- Will short term policies be limited to transitional membership only?
A. Correct. There is no change in the intended use of short term policies.
- Per Bulletin 13‐02, the state allows SHOP rating on a per member basis. Does this also
extend to premium billing as well, or do premium rates have to be billed at the
subscriber level? If subscriber‐level billing is required, can premium rates be billed
separately for different levels of dependent coverage (e.g., Employee Only, Employee &
Child, Employee & Spouse, Employee & Family) or must they be billed for employee
only coverage versus employee plus family coverage (i.e., 2‐tier rating)?
A. As stated in Bulletin 13‐02, small group premiums can be, but will not be required to be based on average enrollee amounts. Per the final market rules, this means that issuers are permitted to develop the premium on a per‐member basis or use average enrollee amounts. Average enrollee amount premiums are permitted as long as the total is equal to the per‐member build up premium total. Average enrollee amounts can be set using multiple tiers (including more than two), as long as the tier factors are standardized and are applied consistently.
About the Department of Insurance
The Idaho Department of Insurance has been regulating the business of insurance in Idaho since 1901. The mission of the Department is to equitably, effectively and efficiently administer the Idaho Insurance Code and the International Fire Code. For more information, visit www.doi.idaho.gov.