The Competitiveness and Transparency Subcommittee was charged with examining howpurchasers and patients in South Carolina and elsewhere currently find health insurance andhealth providers which provide the best value, examine the PPACA health insurance exchangemandate to determine its proposed role in improving value, and make recommendations to theHealth Planning Committee on a recommended course of action.
The committee met eight times between April and November 2011. Its members w
erecomprised of representatives from the provider community, health insurers, the general public,insurance brokers, the legislature and state agencies. Input was achieved through a variety ofmeans: research material of interest was submitted to the sub-committee by individualmembers as background and the Department of Health and Human Services distributed threetimes a week an online
of insurance exchange articles from other states andWashington D.C.; local and national speakers were invited to present to the sub-committee aswere individual subcommittee members; members attended national conferences whichdiscussed or were devoted to health reform and insurance exchanges including severalsponsored by CMS; substantial time for broad discussions during meetings was allowed and allmeetings were open and allowed time for public comment.
The subcommittee's analysis and discussion of the research and testimony leads us to thefollowing three recommendations for consideration by the full Health Planning Committee:
Recommendation 1: The state cannot implement state-based health insuranceexchanges as defined under PPACA and ill-defined and unfinished HHS regulations.
No final rules for the operation of state-based exchange exist and HHS has failed toadequately describe how a federal exchange or hybrid exchange would operate.Committing to either course of action - a state operated exchange or federal exchange -tied into the requirements of PPACA is therefore not desirable. At the subcommittee's lastcount, only 16 states have enacted legislation of any sort related to PPACA and themajority of what has been implemented relates to governance
not operations or insuranceregulation.Timelines for implementation of state or federal exchanges are neither reasonable norachievable. The federal government has already delayed policy making several monthsand policy making is presumably easier than actual implementation which must occur at thestate and federal level and must integrate between state and federal systems. Little, if any,consideration was given at the federal level to the very practical concerns of statelegislative and budgeting cycles or state procurement laws which will impact almost everyaspect of exchange implementation, as well as the very real possibility of months of vendorprotests related to procurement awards. In its timeline planning HHS has ignored years ofnationwide experience with similar implementations of Medicaid eligibility, enrollment and