Healthcare.Gov

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via the Centers for Medicare & Medicaid Services (CMS):

Streamlining Eligibility & Enrollment Notice of Propose Rulemaking (NPRM)

The Centers for Medicare & Medicaid Services’ (CMS’) new proposed rule would make it easier for millions of eligible people to enroll in and retain their Medicaid coverage. The rule would reduce red tape and simplify applications, verifications, enrollment, and renewals for health care coverage through Medicaid and the Children’s Health Insurance Program (CHIP). The proposed rule responds to President Biden’s January 2021 and April 2022 Executive Orders to strengthen Medicaid and access to affordable, quality health coverage.

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via the Centers for Medicare & Medicaid Services (CMS):

  • Historic investment of nearly $100 million builds on the Administration’s quadrupling of Navigators last year to help connect people to coverage

 The U.S. Department of Health and Human Services (HHS), through the Centers for Medicare & Medicaid Services (CMS), is investing $98.9 million in grant funding to 59 returning Navigator organizations for the 2023 Open Enrollment Period to help consumers navigate enrollment through the Marketplace, Medicaid, and the Children’s Health Insurance Program (CHIP) and make health coverage more equitable and accessible to everyone.

Way back in the summer of 2020, then-Presidential candidate Joe Biden rolled out his official healthcare policy proposal. Part of the plan included the following:

Expanding coverage to low-income Americans. Access to affordable health insurance shouldn’t depend on your state’s politics. But today, state politics is getting in the way of coverage for millions of low-income Americans. Governors and state legislatures in 14 states have refused to take up the Affordable Care Act’s expansion of Medicaid eligibility, denying access to Medicaid for an estimated 4.9 million adults.

Biden’s plan will ensure these individuals get covered by offering premium-free access to the public option for those 4.9 million individuals who would be eligible for Medicaid but for their state’s inaction, and making sure their public option covers the full scope of Medicaid benefits. States that have already expanded Medicaid will have the choice of moving the expansion population to the premium-free public option as long as the states continue to pay their current share of the cost of covering those individuals.

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January 10th was the last time that the Centers for Medicare & Medicaid Services (CMS) issued a detailed 2022 Open Enrollment Snapshot report which broke out 2022 ACA enrollment across every state.

As of 1/10/22, it had already reached an all-time record of nearly 14.9 million people (13.8 million via Qualified Health Plans, or QHPs, and another million or so who have enrolled in Basic Health Plans (BHPs) in Minnesota and New York specifically).

A few days later, CMS issued another update just ahead of the official January 15th OEP deadline (in most states) which updated the top line QHP tally to over 14.2 million. They broke this out by "over 10 million" enrollees on the federal exchange (HealthCare.Gov), plus another 4.2 million or more in the 18 states which operate their own ACA exchanges.

Tack on the 1.0M BHPs and that's at least 15.2 million nationally.

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The Affordable Care Act includes a long list of codified instructions about what's required under the law. However, like any major piece of legislation, many of the specific details are left up to the agency responsible for implementing the law.

While the PPACA is itself a lengthy document, it would have to be several times longer yet in order to cover every conceivable detail involved in operating the ACA exchanges, Medicaid expansion and so forth. The major provisions of the ACA fall under the Department of Health & Human Services (HHS), and within that, the Centers for Medicare & Medicaid (CMS)

Every year, CMS issues a long, wonky document called the Notice of Benefit & Payment Parameters (NBPP) for the Affordable Care Act. This is basically a list of proposed tweaks to some of the specifics of how the ACA is actually implemented.

For example, here's what the actual PPACA legislative text itself said about the annual Open Enrollment Period (OEP):

(6) Enrollment periods.--The Secretary shall require an Exchange to provide for--

Last Thanksgiving, regular readers may recall that I went on a bit of a rant regarding the annual Notice of Benefit & Payments Parameters, which is a yearly collection of administrative tweaks made by the CMS Administator regarding the specific way in which a slew of ACA policies are actually implemented.

Out of the dozen or so rule changes included in the 2022 NBPP, several of them were perfectly reasonable; several were fairly nominal or neutral...and several of them should have set off red flags everywhere for the incoming Biden Administration, including:

  • Allowing states to flat-out privatize their ACA marketplaces
  • Pushing navigators and assisters to use private, 3rd-party direct enrollment brokers
  • Codifying the Trump Administration's warped interpretation of ACA Section 1332 waivers

There's also a couple of rules in the 2022 NBPP which I opposed, but which won't cause too much damage (at least relative to the three above):

Three years ago, I posted what seemed to be a fairly naive question:

All of this brings me to my question:

  • Last summer the Trump administration announced that they were slashing their advertising budget by 90%, from $100 million to just $10 million.
  • They also announced that they were slashing $23 million out of the navigator/outreach program for open enrollment.
  • That means they cut HealthCare.Gov's total budget by $113 million.

So my question is this: Where exactly did that money go?

For that matter, assuming HC.gov is set to bring in $300 million more this year, but doesn't plan on reinstating that $113 million for advertising/outreach, doesn't that mean they should be profiting by over $400 million? Again, if so, where is that money going?

Rancid Turkey

UPDATE: It looks like the 2022 NBPP will be open for Public Comment starting on December 4th and ending on December 30th at 5pm. This is obviously 4 days shorter than the typical 30-day minimum, and it includes Christmas Eve & Christmas Day as well. I've been informed that this is technically legal as allowing a minimum of 30 days is a guideline, not requirement...but it sure wouldn't look good if the rule is brought in front of a judge.

The Affordable Care Act includes a long list of codified instructions about what's required under the law. However, like any major piece of legislation, many of the specific details are left up to the agency responsible for implementing the law.

Back in March & April, I wrote a lot about COVID-19 Special Enrollment Periods...and especially about the fact that the largest ACA exchange of all, HealthCare.Gov, kept refusing to do so in spite of massive pressure from governors, members of Congress and nearly every advocacy group under the sun, as well as the U.S. Chamber of Commerce and even the health insurance industry itself...which is especially remarkable given that it was BCBSA & AHIP who insisted on cracking down on Special Enrollment Periods in the first place a few years earlier.

On March 31st, I posted the following:

Back in April, in the midst of the earlier stages of the COVID-19 pandemic sweeping through much of the nation, there was a loud outcry for the various ACA health insurance exchanges, including the federal exchange at HealthCare.Gov which hosts enrollment for over 3 dozen states, to re-open enrollment to anyone who missed the official Open Enrollment Period which had ended several months earlier.

Eventually, twelve of the thirteen state-based exchanges did just that, launching COVID-19-specific Special Enrollment Periods of varying time periods for any resident who would normally be eligible to enroll during Open Enrollment to do so. Many of those SBEs would go on to extend the deadlines of their SEPs by a month...or two months...or even more. As of this writing, in fact, California, Maryland, New York and the District of Columbia are are still offering "open" COVID-19 SEPs.

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