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QHP Issuer Workshop Part II
QHP Application and Review Process Overview, Part II
April 15, 2014
www.pcghealth.com
Schedule and Logistics
QHP Advisory Committee 2
Meeting Information
The meeting will be available in Webex. To join the meeting,
click here and enter meeting password ARQHP. The phone
number to for the voice conference is:
Call-in toll-free number (US/Canada): 1-877-668-4493
Access code: 766 660 437
Proposed Schedule
• 1:30pm – Start meeting
• 2:45pm – 15 Minute Break
• 3:00pm - Resume
• 4:15pm – Wrap up
Agenda
QHP Advisory Committee 3
• Introductions
• Plan Management Updates
• AR 2015 QHP Filing and Certification Requirements
• Review of QHP Bulletin
• Recertification
• Uniform Modification Allowances
• Essential Health Benefits; new considerations
• Quality Improvement Initiatives
• Plan Variations
• Rate Filing
• CMS Review Tools
• Questions?
Plan Management Updates
QHP Bulletin
• The QHP Bulletin was released on Monday, April 14
2015 Final Letter to Issuers
• The 2015 final letter to issuers was released by CCIIO on
March 14 and summarizes plan year 2015 QHP
certification requirements
• The letter can be found here
Network Adequacy Rule
• The AID Network Adequacy rule is expected to be
published within the week (by April 22nd)
QHP Advisory Committee4
Plan Management Updates
• 2014 QHP Application and Certification Timeline – Part I
*AID is requesting that all plan changes be completed by August 6th
to allow time for transmission to HIOS
QHP Advisory Committee5
2014 Key Dates Description
May 1st – June 15th QHP Applications must be submitted to AID by
June 15th
June 16th – August 8th * AID QHP review period
August 11th–August 25th FFM Reviews Plan Data
August 26thFFM Notifies States of any Needed Corrections
to QHP Data
September 4th Last day for issuers to resubmit plan data
September 5th – September
10th2nd SERFF Data Transfer
Plan Management Updates
• 2014 QHP Application and Certification Timeline – Part II
QHP Advisory Committee6
2014 Key Dates Description
September 22nd FFM Completes Re-review of Plan Data and
State Recommendations
September 24th– October 6th Limited Data Correction Window
October 14th– November 3rd
Certification Notices and QHP Agreements
Sent to Issuers, Agreements Signed, QHP Data
Finalized
November 15th Open Enrollment Begins
Plan Management Updates
• Outstanding technical and policy updates that could
impact the timelines:
• Release of 2015 Plan Management Templates (CMS)
• Completion of updated SERFF validation services (expected by
late May)
• Final AID and Health Care Independence Program (“HCIP”,
a.k.a. “Private Option”) QHP certification criteria and details on
cost-sharing variations (expected by May 1)
• Changes to the proposed market standards for 2015 and beyond
(CMS)
QHP Advisory Committee7
Plan Management Updates
Meaningful Difference
• The review process or meaningful difference in plans was
expanded for 2015 and changed slightly from the proposed rule.
• Plans will be segmented by plan type, metal level and
overlapping counties/service areas and then evaluated for
differences in network, formulary, deductibles, MOOP, covered
benefits, HSAs, and availability for children (premiums was taken
out as a criteria)
• Plans are expected to differ in at least one of these areas.
8
Plan Management Updates
Summary of Benefits and Coverage (SBC)
• SBCs are required to be submitted for plan year 2015.
SBCs illustrate benefits and coverage for common
conditions chosen by HHS: Routine maintenance of well-
controlled type 2 diabetes and having a baby (normal
delivery)
• SBCs for plan variations are not required, but are
encouraged. SOBs must be accurate and match policy and
SOB’s information.
9
Plan Management Updates
2015 Plan requirements
• Riders are not permitted to be offered in conjunction
with Marketplace plans, even if the riders are for non-
EHB benefits
• In addition to federal requirements that at least one
silver and at least one gold plan are offered in the
individual market, QHPs in the Arkansas individual
market are required to include at least one silver-level
plan that contains only the EHBs included in the state
base-benchmark plan
QHP Advisory Committee10
Filing and QHP Certification Requirements
QHP Application Process
• QHP applications will be filed through SERFF
• Rate and form filings must both be submitted by the QHP
application deadline (see timelines)
• Individual and small group plans that are only outside the
marketplace are not required to have submitted
applications by the June 15 deadline
• SAD issuers should submit both inside and outside
marketplace plans (that will be certified as a supplement to
EHB)
• SERFF will conduct Issuer trainings April 22-May 21
QHP Advisory Committee11
Filing and QHP Certification Requirements
CMS Onsite Training
• QHP Certification Onsite Technical Assistance Session for
Issuers April 22-23 at CMS in Baltimore
• The purpose of this session is to provide the Issuers and
other entities with information needed for successful QHP
certification
• Register by Thursday, April 17
QHP Advisory Committee12
Filing and QHP Certification Requirements
Recertification
• The CMS 2015 Final Letter to Issuers indicates that the
recertification process will largely resemble the initial
certification process and that all application materials must be
re-submitted
• A recertified plan can keep the same plan and HIOS ID, and
enrollees will remain enrolled into the new benefit year
• Plans that issuers are proposing to recertify will remain in
effect into the new benefit year unless the enrollee terminates
their policy
• Applications for recertification should include a redlined
version of the plan forms and a written justification for any
changes to cost-sharing and covered benefits (A template for
submission of plan change justifications will be posted in
SERFF)
QHP Advisory Committee13
Filing and QHP Certification Requirements
Uniform Modification
• Plans with “uniform modifications” are allowed to be renewed and
recertified if the change is pursuant to Federal or state law, such as
increasing annual limitations on cost-sharing as a result of the
application of the premium adjustment percentage.
QHP Advisory Committee14
Filing and QHP Certification Requirements
Uniform Modification
• If changes are made to the plan that not due to Federal and
state law, then they may still meet the uniform modification
criteria if the plan:
• Is offered by the same health insurance issuer and is the same
product type (i.e. PPO or HMO);
• Covers a majority of the same counties in its service area;
• Maintains the same cost-sharing structure, except for actuarial
adjustments that are a result of cost and utilization of medical
care or in order to maintain the same A/V level of coverage; and
• Provides the same covered benefits, unless changes to benefits
impact the rates only ± 2%.
QHP Advisory Committee15
Filing and QHP Certification Requirements
Uniform Modification – FAQs
Q1: Do changes to plans such as inclusion of mandatory benefits
like TMJ and hearing aids, changes to a plan to meet the EHB-only
silver plan requirement, changes to HCIP cost-sharing
requirements, and removal of riders count as a uniform
modifications?
A1: These changes are pursuant to changes in federal and state
law and guidance and are considered uniform modifications
Q2: Will changes to non-EHB benefits violate uniform modification
criteria?
A2: If the changes to non-EHBs affect the plan index rate by more
than 2%, it will not be considered a uniform modification.
QHP Advisory Committee16
Filing and QHP Certification Requirements
Uniform Modification – FAQs
Q3: To what extent is a change to MOOP allowed and it still be
considered pursuant to federal law (due to annual increase in
MOOP in the 2015 benefit and payment parameters)?
A3: CMS has recently indicated that in order to qualify as a uniform
modification, the change must be pursuant (required) by law, so a
change in plan MOOP due to annual increase in the maximum
allowable MOOP levels would not be considered a uniform
modification. AID is submitting comments on the proposed market
standards and will indicate this suggested clarification in the final
rule.
QHP Advisory Committee17
Filing and QHP Certification Requirements
Certification Standards Applicable to Stand-alone Dental
Plans
QHP Advisory Committee18
Certification Standard Applies (* denotes modified standard)
Certification Standard Does Not Apply
Essential Health Benefits*
Actuarial Value* Accreditation
Annual Limits on
Cost Sharing*
Licensure Cost-sharing Reduction Plan Variations
Network
Adequacy
Inclusion of ECPs Unified Rate Review Template
Marketing Service Area Meaningful Difference
Non-discrimination
Filing and QHP Certification Requirements
Associated Schedule Items
• QHP forms and associated documentation should be
attached to the binder through SERFF Plan Management
functionality. All applicable forms must be attached to the
correct plans in the binder.
• The SERFF instructions for associated schedule items can
be found here.
QHP Advisory Committee19
Essential Health Benefits
• The QHP Issuer must offer coverage that is substantially equal to
the coverage offered by the state’s base benchmark plan and
attest that plans are in compliance with all EHB standards.
• Benefits and coverage requirements for the AR Benchmark Plan
can be found in the QHP Checklist and AR Essential Health
Benefits Guidelines (see Attachment D).
QHP Advisory Committee20
Essential Health Benefits
Mental Health Parity
• MHPAEA requires that treatment limitations (whether quantitative or non-
quantitative) for MHSA benefits are no more restrictive than the
predominant requirements or limitations applied to substantially all
medical/surgical benefits.
Mental Health Benchmark Requirements
• The AR benchmark coverage for mental health is based on the
QualChoice federal employee benefits health plan. However, the non-
quantitative treatment limitations in the mental health and substance
abuse benchmark plan may not meet the MHPAEA; issuers must ensure
that the quantitative and non-quantitative treatment limitations in MHSA
coverage comply with MHPAEA requirements.
• For example, the benchmark plan states that all services require
preauthorization and an approved treatment plan, and this would not be
permitted under MHPAEA unless the same limitation applies to substantially
all medical and surgical benefits in the benefit category.
QHP Advisory Committee21
Essential Health Benefits
Mental Health Parity and AR Network Adequacy Standards
• Network adequacy- Mental Health, Behavioral Health and
Substance Abuse access standard was previously 45 minutes or
45 miles. Due to updates in the mental health parity rule and
confirmation from CCIIO, the standard has been changed to 30
minutes or 30 miles. It is understood that in some areas of the
state, there are not sufficient providers to meet this standard.
QHP Advisory Committee22
Essential Health Benefits
Prescription Drugs
• CMS noted in the letter to issuers that the agency intends to
review plans that are outliers based on an unusually large
number of drugs subject to prior authorization and/or step therapy
requirements in a particular category and class.
• CMS also expects the URL link to direct consumers to an up-to-
date formulary where they can view the covered drugs, including
tiering, that are specific to a given QHP.
• The URL provided to the Marketplace as part of the QHP
Application should link directly to the formulary, such that
consumers do not have to log on, enter a policy number or
otherwise navigate the issuer’s website before locating it. If an
issuer has multiple formularies, it should be clear to consumers
which formulary applies to which QHP(s).
QHP Advisory Committee23
Essential Health Benefits
Arkansas Habilitative Services
Definition of Habilitative Services
• Habilitative services are services provided in order for a person to
attain and maintain a skill or function that was never learned or
acquired and is due to a disabling condition
Coverage of Habilitative Services
• Subject to permissible terms, conditions, exclusions and limitations, health
benefit plans, when required to provide essential health benefits, shall provide
coverage for physical, occupational and speech therapies, developmental
services and durable medical equipment for developmental delay,
developmental disability, developmental speech or language disorder,
developmental coordination disorder and mixed developmental disorder.
QHP Advisory Committee24
Essential Health Benefits
Arkansas Habilitative Services
Establishing Parity
• QHPs must offer habilitative services at parity with rehabilitative services.
Because developmental services are generally less expensive and required
on a long-term basis, the department has determined that parity must be
established through the use of unit equivalency. All medical QHPs must
include developmental services with unit limits at an acceptable level of parity
with Outpatient and Inpatient Rehabilitation for the 2015 plan year policies.
The minimum acceptable limits are included in the table below:
QHP Advisory Committee25
Rehabilitation
(OT, PT, ST)
Habilitative Services
(OT, PT, ST)
Habilitative
Developmental
Services
Outpatient
30 visits
(1 visit = 1 unit = 1
hour or less)
30 visits
(1 visit = 1 unit = 1hour or
less)
N/A
Inpatient 60 days N/A 180 units (1 unit = 1 hour)
Essential Health Benefits
Mandated Offerings as EHBs
• Due to Arkansas statutory language and the CCIIO requirement that
riders are not allowed with any filing, TMJ and Hearing Aids will be
considered Mandated Benefits and must be embedded in all QHPs,
unless the plan is an HMO not subject to the AR mandatory hearing aid
offering requirement (Bulletin 7-A 2009)
In-vitro Fertilization
• In-vitro is a mandated AR benefit so must be embedded in all QHPs
(except HMOs) even though it is not included in the state benchmark
plan
QHP Advisory Committee26
Essential Health Benefits
New AR-Mandated Benefits
• AR mandated benefits enacted after December 2011 are
considered in addition to EHB and must be excluded from the
silver EHB-only plan and excluded from premium allocated
towards EHBs in the actuarial memorandum. Act 1226 of 2013
enacted a new mandated benefit for Craniofacial surgery.
• These additional laws were enacted in 2013 and apply to existing
mandated benefits:
• Act 1259 of 2013: Mammography reimbursements
• Act 342 of 2013: Physical therapists must be paid the same as
general practice doctors
• Act 464 of 2013: Must have review process for excluded services
that are experimental
• Act 1233 of 2013: Revised coverage for orthotics
QHP Advisory Committee27
Essential Health Benefits: Cost Sharing
Maximum Out of Pocket Limits*
• Note that OON Emergency Services can count towards in-
network MOOP
* Based on Final 2015 Benefit and Payment Parameters
QHP Advisory Committee28
Medical Dental
Individual $6,600 $350
Family $13,200 $700
QHP Quality Requirements
Three Quality Goals:
• #1 - Inform Plan Certification – Includes QHP certification
standards, issuer quality improvement practices, and safety
• #2 - Provide Information to Consumers for Plan Selection –
Includes quality rating system and enrollee satisfaction surveys
• #3 - Monitor Plan Quality - Oversight and monitoring to include
complaints and appeals data, disenrollment information, and denied
claims
QHP Advisory Committee29
QHP Quality RequirementsGoal #1 - Inform Plan Certification – Includes QHP certification standards,
issuer quality improvement practices, and safety
Areas with current federal guidelines:
• Accreditation
• Patient Safety (may be more in the future)
Areas pending guidelines:
• Submission of Plan Performance
• Pediatric quality reporting measure
• Quality improvement strategy
While there is not yet federal guidance in some of these areas, QHP issuers are
required to participate in the AR Payment Improvement Initiative as a current
QHP certification standard, including the AR Patient-Centered Medical Home
Model in alignment with Medicaid PCMH standards.QHP Advisory Committee
30
QHP Quality RequirementsGoal #2 - Provide Information to Consumers for Plan Selection
Areas with current federal guidelines:
• Proposed Quality Rating System Guidelines
• Proposed Enrollee Satisfaction Surveys
AID gathered input from stakeholders via the PMAC quality
subgroup and submitted comments on the initial QRS proposed rule.
Additional details regarding the rating methodologies were published
recently and can be found here (CMS Health Insurance Marketplace
Quality Initiatives website).
QHP Advisory Committee31
QHP Quality RequirementsGoal #3 - Monitor Plan Quality
Areas with current federal guidelines:
• Review of complaints and appeals as part of Accreditation requirements
Areas pending guidelines:
• Submission of disenrollment information and denied claims
AID conducts quarterly audits of Qualified Health Plans and quality
components will be included in the audits. QHP issuers are required
to submit requested data to AID in the oversight and monitoring
process.
QHP Advisory Committee32
Additional Updates
Third Party Payment of QHP Premiums
• CMS has published an interim final rule in 45 CFR §156.1250
regarding acceptance of certain third party payments. Issuers are
required to accept premiums from Ryan White HIV/AIDS
programs, Indian tribal organizations, and State and federal
government programs (such as the HCIP program)
QHP Advisory Committee33
Additional Updates
AID Bulletin 8-2013 regarding Marketing Standards
• QHP Issuers are prohibited from using a design of a program, entity
name, webpage, or internet solicitation intended to look like
Healthcare.gov, ARHealthconnector.org or Access Arkansas; nor shall a
person or entity create any name, logo, symbol, or web address of any
kind which is similar enough to mislead a consumer to believe it is a
direct pathway for purchase of qualified health plans offered in
Healthcare.gov, ARHealthconnector.org or Access Arkansas.
• QHP Marketing materials must be submitted to AID prior to use.
QHP Advisory Committee34
Z L
73 = 73% A/V Silver Variation
87 = 87% A/V Silver Variation
94 = 94% A/V Silver Variation
L= Limited Cost Sharing Variation
Z= Zero Cost Sharing Variation35
Z = Zero Cost Sharing Variation
L = Limited Cost Sharing Variation
CatastrophicStandard
Bronze
Standard
Silver
Standard
Gold
Z L Z L Z L
8773 9494
What about HCIP? Standard
Platinum
Plan Variations
Z
Catastrophic and Standard Plans
The Catastrophic Plan:
• Has an actuarial value of < 60%
• Is not required to have a Zero or Limited Cost Sharing Variation
The “Standard” Plans:
• Have actuarial values of 60%, 70%, and 80%, and 90% for
Bronze, Silver, and Gold and Platinum, respectively.
• Must include at least one Silver and one Gold plan for each
issuer.
36
Zero Cost Sharing Variation
The Zero Cost Sharing Variation:
• Is required for the Bronze, Silver, and Gold Plans
• Is for the purpose of removing all cost sharing for EHB
services for Indians up to 300% FPL.
• Must have zero cost sharing for both in and out of network
services.
• Is not offered in SHOP.
• Is used in the HCIP for individuals 0-100% FPL in plan
year 2014. Out of network cost sharing is not allowed in
the HCIP.37
Limited Cost Sharing Variation
The Limited Cost Sharing Variation:
• Is required for the Bronze, Silver, and Gold Plans
• Is for the purpose of removing cost sharing for EHB
services furnished by Indian Providers for Indians
regardless of income (over 300% FPL since below 300%
FPL will be covered by the Zero Cost Sharing variation).
• Looks just like the corresponding Bronze, Silver, and Gold
standard plan in the templates.
• Is not offered in SHOP.
38
Silver Plan Variations Part I
The Silver Plan Variations:
• Reduce cost sharing and MOOP amounts for
individuals up to 250% FPL.
• Must first increase actuarial value by reducing
MOOP, then increase actuarial value by reducing
cost sharing (copays and coinsurance).
• Are allowed to have out of network cost sharing.
• Must have equivalent non-EHB cost-sharing to
the corresponding standard silver plan.
• Are not offered in SHOP.
39
73 = 73% A/V Silver Variation
87 = 87% A/V Silver Variation
94 = 94% A/V Silver Variation
Silver Plan Variations Part II
The Silver Plan Variations are determined
according to income. Lower income individuals
qualify for higher cost sharing reduction plans
with higher A/V.
40
73 = 73% A/V Silver Variation
87 = 87% A/V Silver Variation
94 = 94% A/V Silver Variation
(a.k.a. “High Silver”)
94%87%
73%150% FPL
200% FPL
250% FPL
Silver Plan Variations Part III - MOOP
The Maximum Out of Pocket (MOOP) amounts
are required to be reduced for silver plan
variations. CCIIO may change these reduction
amount requirements over time.
41
73 = 73% A/V Silver Variation
87 = 87% A/V Silver Variation
94 = 94% A/V Silver Variation
(a.k.a. “High Silver”)
94%87%
73%150% FPL
200% FPL
250% FPL
The MOOP allowance for the standard silver
plan is $6,600 (2015). The MOOP reduced
allowances for 2015 are shown above
(tentative).
$2244$3300
$3300
HCIP Variations Part I
• HCIP uses Silver plan variations only.
• For plan year 2014, the plans used for
HCIP include the Zero Cost Sharing plan
and the 94% High Silver plan.
• The Zero Cost Sharing plan is not allowed
to have Out of Network cost sharing.
• The 94% High Silver Plan is given
specific cost sharing requirements (
Appendix E in the plan year 2015 QHP
Bulletin).
• The 94% high silver plan is allowed to
have OON cost sharing and was not
modified for the HCIP.
42
73 = 73% A/V Silver Variation
87 = 87% A/V Silver Variation
94 = 94% A/V Silver Variation
Z = Zero Cost Sharing Variation
L = Limited Cost Sharing Variation
HCIP Variations Part II
• The variations that apply to HCIP are shown
below. The Actuarial Value is shown below
each of the “steps” and the applicable income
level by percent FPL is shown above each of
the steps. The silver plan variation with a 94%
A/V is shared between the HCIP program and
FFM.
43
73 = 73% A/V Silver Variation
87 = 87% A/V Silver Variation
94 = 94% A/V Silver Variation
Z = Zero Cost Sharing Variation
L = Limited Cost Sharing Variation
100%94%
87%73%
151-200%
201-250% FPL
0-100% FPL
Zero Cost Sharing Plan (Z2)
HCIP FFM
94% Actuarial Value Plan
HCIP Variations Part III
Issuers submit separate benefit summaries
for plan variations, including HCIP variations.
The form requirements include:
• Limited Cost Sharing Plan Variation
• HCIP Zero Cost Sharing Plan (matches the
Marketplace plan other than potential
differences in title)
• Zero Cost Sharing Plan for Indians up to 300%
FPL
• 73% A/V Cost Sharing Variation
• 87% A/V Cost Sharing Variation
• 94% A/V Cost Sharing Variation
73 = 73% A/V Silver Variation
87 = 87% A/V Silver Variation
94 = 94% A/V Silver Variation
Z = Zero Cost Sharing Variation
L = Limited Cost Sharing Variation
Plan Variation Naming Conventions
Naming Conventions:
Naming conventions will be required for plan schedules of
benefits:
Schedules should be named in the following way:
Sch- + [-Component Plan ID-] + [Variation ID]
For example: Sch-15234AR0070003-01
QHP Advisory Committee45
Summary of Plan Variations
46
• Zero Cost Sharing Variation: removes all cost sharing for EHB
services for Indians up to 300% FPL; must have zero cost sharing
for both in and out of network services.
• Limited Cost Sharing Variation: removes cost sharing for EHB
services furnished by Indian Providers for Indians regardless of
income.
• Silver Plan Variations: 73%, 87%, 94%. Reduce cost sharing
and MOOP amounts for individuals up to 250% FPL; are allowed
to have out of network cost sharing.
• Plans Used for HCIP:
• Zero Cost Sharing
• 94% Silver Variation
HCIP 94% A/V ("High-Silver") Cost Sharing
QHP Advisory Committee47
• The AID Bulletin includes the
required HCIP cost-sharing
options for high-silver 94%
A/V plans.
• Additional guidance with
specific cost-sharing guidance
is expected prior to May 1st.
The guidelines are expected
to align with benefits in the
templates.
• The cost-sharing
requirements are similar to
last year, with the exception of
the removal of the emergency
copay.
Rate Filing
Filing for Actuarial Rate Review:
• The process will be similar to last year; issuers submit the
actuarial memorandum and rates will be reviewed for all
QHPs (except SADPs)
• Carriers need to ensure that actuaries are available for
questions and discussions during the QHP review period
and can respond within 48 hours
QHP Advisory Committee48
Rate Filing
Issuers must submit all required rate review documentation, including:
QHP Advisory Committee49
Part I - Unified Rate
Review (URR) Template
Rate Review Template developed by
HHS. The updated template can be found
here.
Part II Consumer
Justification Narrative-
Justification information
received for rate
increase, if applicable.
Justification narrative for rate increases
(that exceed 10% threshold)
Part III Actuarial
Memorandum
Rate filing documentation to support QHP
rates and all rate increases. A
supplemental actuarial variation
spreadsheet form required for AR rate
reviews can be found in Attachment L.
Rate Filing
Additional rate filing updates:
• Rate increases over 10% are required to be filed in HIOS. CMS
has indicated that rate increases must be filed and approved by
the state in the HIOS system before the rates can be shown
correctly on Healthcare.gov.
• A field to indicate premium allocation towards EHBs has been
added in the proposed benefits and cost-sharing template. This
must be completed and must align with information in the
actuarial memorandum.
QHP Advisory Committee50
Review Tools
• Issuers will have access to the QHP Application Review Tools this
year and we recommend issuers take advantage of these tools
for a smooth certification process
• These tools are a method for reviewing against specific standards
such as the 30% threshold for ECPs, annual limitation on cost
sharing, catastrophic plan requirements, etc.
• The Data Integrity Tool (DIT) is specifically designed for issuers to
(1) provide a method for issuers to check that the data contained
in their templates is in the correct format; and (2) provide issuers
with feedback immediately and reduce resubmissions
QHP Advisory Committee51
Overview of QHP Application Review Tools
Select Market Reform
Standards
Marketplace-Specific
Standards
• Actuarial Value
• Annual limitation on
Cost Sharing (i.e. EHB
out-of-pocket
maximum)
• Catastrophic Plan
Requirements
• EHB Discriminatory
Benefit Design
• Formulary-USP
Category Class Count
• Non-discrimination
Formulary Outlier
• Non-discrimination
Formulary Clinical
Appropriateness
• Accreditation
• Cost Sharing Reduction
Plan Variation
Requirements
• Essential Community
Providers
• Meaningful Difference
• Program Attestation
• Service Area
• SHOP tying provision
• Non-discrimination Cost
Sharing Outlier
QHP Advisory Committee52
Questions?
QHP Advisory Committee53
Attachment Index
A. 2015 Final Letter to Issuers
B. SERFF Filing Instructions
C. Arkansas Health Plan Submission Requirements
D. QHP Checklist and AR Essential Health Benefits Guidelines
E. USPSTF preventive health benefits guide
F. USPSTF Tobacco Cessation Recommendations
G. Network Adequacy Checklist
H. State benchmark plans
• Medical-BCBS Health Advantage POS
• Mental Health and Substance Use Disorder-QCA FEHBP
• Pediatric Vision-CHIP (AR Kids B)
• Pediatric Dental-CHIP (AR Kids B)
I. Benchmark drug formulary
QHP Advisory Committee54
Attachment Index
…continued
J. URRT and Instructions
K. Uniform Certificate of Authority Application “UCAA”.
L. AR Actuarial Memorandum Form
M. Uniform Modification Recertification Form
N. AID QHP Bulletin 9-2014
QHP Advisory Committee55
56
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