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Council Letter to Rothman

Council Letter to Rothman

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Published by crichert30

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Published by: crichert30 on Nov 18, 2013
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11/25/2013

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M
 I N N E S O T A
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M
INNESOTA
55114
 
651-645-0099 FAX 651-645-0098
 
Blue Cross and Blue Shield/Blue Plus of Minnesota
 HealthPartners
 Medica Metropolitan Health Plan
 PreferredOne
 Sanford Health Plan of Minnesota
 UCare
 
 November 18, 2013 Commissioner Michael Rothman MN Department of Commerce 85 Seventh Place East, Suite 500 St. Paul, MN 55101-2198
RE: November 15
th
 ACA Announcement by President Obama Dear Commissioner Rothman: Thank you for the opportunity to meet
with your staff on Friday regarding President Obama’s offer to allow a
 one-year delay in implementing general Affordable Care Act (ACA) requirements. As a follow up to the meeting, this letter outlines our most serious concerns and barriers with changing course this late in the process. Unlike many states, Minnesota embraced health care reform and has worked for years to move toward a marketplace that is fair and consistent for all Minnesotans. As a state we are ready for reform. We are concerned that President Obama's offer to allow the resale of non-ACA compliant policies cannot be implemented fairly for Minnesota consumers, and if allowed, would threaten out state's ability to successfully implement the ACA.
While we understand that many consumers are frustrated that their health coverage is changing, the
President’s offer for a one
-year delay will not erase their frustration
 — 
it will only postpone it to the fall of 2014 when those policies must be brought into compliance
. In the face of significant risk to our state, we struggle to see a benefit for our state to justify allowing the President's proposal to move forward. As you make your final decision, we urge you to consider the following issues:
 
If the President’s offer is accepted, already approved
2014 rates will be invalid.
 New rates for products already on the market will need to be refiled and reapproved. If rates are not allowed to be refiled, they will  be insufficient and each carrier will independently need to assess what this means going forward.
 
Having been notified in September and October that their 2013 policies couldn’t be renewed as is,
many Minnesotans already shopped and compared new coverage options both inside and outside MNsure.
 Thousands have purchased new coverage and others are prepared to do so by the Dec. 15 federal and state deadline. Going backward on such a very tight timeline will create uncertainty, confusion and disruption when people seek care.
 
 
Page 2 Commissioner Michael Rothman  November 18, 2013
 
President Obama’s an
nouncement was, of course, at a very high level. The details that followed from Center for Medicare and Medicaid Services (CMS) present legal and regulatory barriers that are unique to Minnesota.
The President’s offer applies only to individuals and small bu
siness who received a
cancellation or termination notice
.
Due to Minnesota’s guaranteed renewability laws, products were not
canceled or terminated.
 
 
Health plan information technology, administrative obstacles will make implementation of a change uneven and therefore unfair for consumers
. The policies as they exist today are no longer in the systems. In addition, rebuilding the systems would require the very same staff currently working to ensure a successful Jan. 1, 2014, implementation of MNsure-related policies to refocus their work on rebuilding 2013 system capability. Health plans would not be able to evenly administer a change of this magnitude creating an unfair situation and additional confusion. Below I offer additional context and detail for each of the issues noted above.
Market stability, rates, MNsure and competition
 
Implementing two parallel individual markets with inconsistent rules creates significant differences in consumer choices, products and access to providers.
 
The risk of disruption and destabilization of the entire market is significant. Rebuilding market assumptions, rating and filings is simply not achievable at this late date. Market rates and policies for 2014 were established based on rules set forth by not only the federal government but also by the state of Minnesota. If rules change now, the 2014 rates would not be sufficient. Refiling of forms and rates for 2014 new products and reformed-renewals will likely result in premium increases across the board. If health plans are not allowed to refile, the market will not be stable and could result in financial concerns for health plans companies as they begin the 2015 rate-setting process. This uncertainty could lead some plans to reconsider their participation in 2014 either on or off the Exchange, or both. The effects of such a policy change to the risk pools are real and cannot be ignored by the health plans.
 
There is already significant uncertainty facing the 2015 individual market with the closing of Minnesota Comprehensive Healthcare Association at the end of 2014. We cannot support adding more complexity to the 2015 marketplace.
 
 
Page 3 Commissioner Michael Rothman  November 18, 2013
 
Currently, members with the products that are noncompliant for 2014 are included in the risk pool with MNsure and outside-of-
MNsure individual market enrollees. If the President’s offer is accepted, these
enrollees would not be in that risk pool, causing even greater premium increases for those in the pool.
 
Healthier and/or younger enrollees who have 2014 noncompliant plans are unlikely to give up their coverage for something unknown, especially if they do not receive a tax credit to help pay the premium. This will negatively impact the prices for all policies in 2015.
 
A change in market rules impacts more than just the 140,000 Minnesotans who were in individual market  policies that had to be updated for 2014. The issue also affects the small group market. The domino effect on  pricing reaches enrollees across the entire marketplace.
 
Health plans prepared for the 2014 individual market and competitively priced their products. One company entered the individual market for the first time, based on the rules set forth for the entire marketplace. Changing the rules less than a month before the enrollment deadline is anti-competitive.
Creating unnecessary confusion
 
Due to the fact that the timeline does not allow changes to be implemented and member ID cards and other materials to be distributed before January, there will be a disruption when people seek care.
 
Health plans have already received calls from members who want to keep 2013 products and receive a
refund from MNsure. Because the President’s offer does not apply equally to all products, consumers will be
confused.
 
Confusion may lead some consumers to wait out the uncertainty and therefore miss the Dec. 15 enrollment deadline, leaving them uninsured in January 2014.
 
 Not all policies available in 2013 are available in 2014. For example, an individual may have a network  provider under t
heir 2013 policy who is not in the health plan’s network in 2014. It is not fair to offer
options to some enrollees but not to others.
 
The details around “Keep what you have” is very conditional. These details make it confusing for consumers
and brokers or others who work with them. It also will lead to dissatisfaction next year. Some consumers may be able to keep their plan, but:

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