Michigan's Department of Insurance and Financial Services releases an annual bulletin asking carriers to submit their forms and rates for on-Marketplace and off-Marketplace plans. While the bulletin doesn't cover all rules and regulations (CMS's Notice of Benefit and Payment Parameters is a better source), it provides insight into the state's priorities for the upcoming plan year. So, what's important to the state? And how will it affect health insurance agents?
CMS limits non-standard plan offerings...
Carriers can only offer two non-standard plans per network and metal level, unless they qualify for an exception. There won't be standardized options for non-expanded bronze plans, and all standardized plans will include some preventive drugs with zero cost share in Tier One.
...But will allow some exceptions
CMS allows carriers to exceed the plan limit if they can show their benefit design treats chronic and/or high-cost conditions at 25% less cost-sharing than other non-standard plans. Prescription drug costs are included in this calculation, so carriers may target chronic conditions by re-shuffling high-cost drugs into lower tiers.
Michigan expands the types of providers it will look for in assessing network adequacy
13 new specialties will be added to DIFS' network adequacy guidelines. A full list can be found in the bulletin. The state will ensure sufficient numbers of specialists like anesthesiologists, optometrists, dental oral, and maxillofacial surgeons, and certified nurse midwives are in-network before allowing carriers to operate in those areas. Some carriers may need additional specialists to begin or continue offering plans in a given county.
Form and filing deadlines are creeping up
Deadlines are approaching – May 15 for small-group ACA plans and May 29 for individual issuers. Plans, DIFS, and CMS will exchange data over the next several months to ensure compliance. By October 2, CMS will finalize agreements with compliant issuers, just in time for Open Enrollment on November 1.
Why it matters
DIFS seems intent on building its vision of a more consumer-friendly market by limiting plan choices, allowing exceptions for plans targeting chronic conditions, and beefing up network adequacy standards. Whether these moves will produce the desired outcome remains to be seen.
Action Benefits : Jan 04, 2023
Action Benefits