Plan Management Part 3 – Interim Procedures Producer Appointment Presentation to: Exchange Board of Trustees May 14, 2013 A service of Maryland Health Benefit Exchange
Plan Management Guiding Principles The Maryland Health Benefit Exchange will use the following guiding principles to establish its approach to Plan Management: • Promote affordability for the consumer and small employer • Ensure access to quality care for consumers presenting with a range of health statuses and conditions • Facilitate informed choice of health plans and providers by consumers and small employers • Reduce health disparities and foster health equity
Plan Management Interim Procedures Interim Procedures cover the essential steps needed for carriers to offer health plans on the Maryland Health Connection. Interim procedures will guide the initial year of qualified plan development and oversight. Part 1 Policies and Interim Procedures were adopted by the Exchange Board and have been published: – Plan Certification – Plan Recertification – Plan Decertification – Plan Submission Limits Part 2 Policies and Interim Procedures for were adopted by the Exchange Board and have been published: – Dental & Vision Plan Offering and Price Display – Producer Incentives
Plan Management Interim Procedures Today’s discussion will focus on Part 3 of the Policies and Interim Procedures - Producer Appointments Producers will play a critical role in helping the Maryland Health Benefit Exchange (MHBE) enroll uninsured consumers in plans offered through Maryland Health Connection. The Producer Appointment policy will impact how many producers will be able to sell plans for the state-based exchange.
Policies & Procedures - Development Pathway • Patient Protection & Affordable Care Act Identify • Exchange Final Rule federal & State • CCIIO State-Based Exchange certification requirements requirements. • Maryland Health Benefit Exchange Act of 2012 • Carriers • Consumers Identify • Providers stakeholders? • State Agencies • Legislative Committees • Best practices What are the • Opportunities for improvement current market • Inside/outside Maryland policies? • Policy Options Develop Exchange • Basis for interim procedures • See Appendix Specific Policies • Reduce redundancy Develop draft • Leverage existing expertise interim • Address Maryland specific requirements procedures • Align with guiding principles • Pros/cons of draft Obtain feedback procedures from • Additional considerations stakeholders Final Interim Procedures
Final Interim Procedures Part 3 6
Final Interim Procedures – Part 3 The draft version of the Interim Procedures was posted on the MHBE stakeholder web site for public comment – March 7 th - March 21st Stakeholders were invited to provide comments – Producers – Carriers – Consumer Advocates – Legislative Committees • Joint Committee on Administrative, Executive and Legislative Review • Senate Finance Committee • House Health and Government Operations Committee
Final Interim Procedures – Part 3 Written Comments The following organizations submitted written comments on the draft version of the interim procedures – CIGNA – UnitedHealthcare – Advocates fro Children & Youth; Maryland Women’s Coalition for Health Care Reform – Independent Insurance Agents and Brokers of America; Independent Insurance Agents and Brokers of Maryland & Insurance Agents & Brokers of Maryland – Maryland Insurance Administration – House Health & Government Operations Committee The MHBE staff reviewed the comments and incorporated the feedback into the final interim procedures wherever possible. 8
Final Interim Procedures – Part 3 Stakeholder Feedback Remove the distinction between point-of-sale and non point-of-sale appointments Grounds for denying appointments should be consistent with those identified for SHOP Navigators More time is needed for carriers to respond to a request for appointment Carriers must track and report to MHBE authorized producers that are appointed Clarify terminology “carrier certification” vs. “carrier authorization” 9
Final Interim Procedures - Summary A carrier must appoint an authorized producer within 10 business days of receipt the request A carrier must appoint every authorized producer – unless reasons specified under 31112(e)(1), Annotated Code of Maryland A carrier can not deny appointment based on production volume A carrier can not impose a production requirement A carrier must allow authorized producers to discuss all Maryland Health Connection plans with or without an appointment A carrier must provide a basis for denial to the authorized producer within 10 business days Dispute resolution will be managed by the MIA – While the dispute is being reviewed by the MIA, the producer can continue to sell and enroll individuals and small businesses A carrier can limit the scope of an appointment to only Maryland Health Connection A carrier must provide information on their producer register upon request of the MHBE 10
Questions from the Board? 11
Resolution to Adopt Interim Procedures 12
Thank you! For questions on the information contained in this presentation, please contact: Tequila Terry Director, Plan & Partner Management Maryland Health Benefit Exchange Email: Tequila.Terry@maryland.gov www.MarylandHBE.com 13
Appendix 14
Producer Appointment - Initial Recommendation Federal and/or State Requirements Options Producer engagement will be critical to the success of Maryland Health 1. MHBE Decision Model Connection. Because of this, MHBE needs to establish a policy to define how the Producer distribution channel will be built and 2. Common Set Model managed for Maryland Health Connection. 3. Shared Decision Model The Maryland Health Benefit Exchange Act of 2012 requires Producers to present all options available to employees in the SHOP and all 4. No Appointment Required options available to the small employer. 31-112(G) (2) (III) 5. Hybrid Model Additional specificity is needed to determine which Producers will be appointed to enable Producers to present all Maryland Health Connection plan options to consumers. Key Considerations Recommendation Current Market Practice Option 5 – Hybrid Model Today, Producers make up a key distribution channel for carriers. Decisions on who can sell their products is a core business function for carriers. Producers are required to be “appointed” by carriers in order to sell their products. Some carriers may require a production goal to be Evaluation & Reassessment: met to maintain appointment status. For year two, MHBE will determine if modifications to the Producer Appointment policy should be made. Employee Choice in the SHOP The Maryland Health Benefit Exchange Act of 2012 requires Producers to present all options available to employees and employers. 31-112(G) (2) (III) The Employee Choice model of the SHOP Exchange requires that Producers be able to present all carrier plans. State Role/Resources Historically, the State has not been involved with carrier decisions to accept/decline Producers. Additionally, MHBE has limited resources to 15 take over this function for carriers.
Producer Appointment – Initial Recommendation Option 5 The MHBE producer authorization process would be performed separately from carrier appointment. “Hybrid Model” Producers would be required to inform consumers about all Maryland Health Connection options as a condition of MHBE authorization. Producers not appointed by all carriers would be required to provide a disclosure to consumers about the inability to complete sales for all plans. Carriers would be required to appoint producers at the point of sale unless there was cause to exclude the producer. For producers who applied for appointment outside of a point of sale, carriers would be allowed to use their current criteria for evaluating producer appointments, with the following exceptions: • Carriers could not decline to appoint based on the failure of the producer under a current or previous appointment to achieve a certain level of production. • Carriers could not impose production volume requirements in evaluating producers selling Maryland Health Connection plans. • Carriers also would be permitted to limit the scope of a producer appointment to Maryland Health Connection business only if they wish to do so. For a carrier that declines to appoint a producer or seeks to terminate a producer, the carrier would be required to provide a mechanism for the producer to request a decision reconsideration. If after reconsideration, the dispute is not resolved, the MIA would resolve any dispute regarding a carrier that declines to appoint a producer or seeks to terminate an 16 appointment.
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