The Center for Medicare and Medicaid Services released a proposed rule for the PPACA Exchanges this morning. These are my initial thoughts that I will most likely change as more information comes in and points are clarified. This rule is fundamentally a technical corrections rule that seeks to make the Exchanges work while favoring insurer interests. It is not a rule that will blow up the Exchanges.
The rule can be broken into two broad segments. The first segment is premium decreasing measures through plan design. This segment seeks to lower the cost of premiums (and incidentally, the cost of premium tax credits) by slightly dropping minimum requirements of coverage. This will benefit healthier individuals who do not receive subsidies and it will disadvantage sicker and more expensive individuals who are subsidized.
The second and far broader portion of the rule is risk pool management functions. The rule making assumes that there is significant intentional gaming of the various enrollment rules which have led to an adversely ill and expensive risk pool as healthy people are finding ways to avoid paying for coverage until
Larry Levitt at the Kaiser Family Foundation has a good general take on the rule making direction.
The Trump Administration’s ACA rules strike me as making things less consumer friendly and more insurer friendly. https://t.co/YisMncHVya
— Larry Levitt (@larry_levitt) February 15, 2017
Now let’s dig into the details.
First thoughts on CMS-9929-P proposed rulePost + Comments (17)