- The Colorado Division of Insurance and Governor's office will decide whether to allow the sale of non-ACA compliant health plans beyond 2014. A decision has not yet been made and may require legislative action.
- Stakeholders expressed differing views on whether non-ACA plans should be allowed to be sold. Consumer advocacy groups opposed the idea due to potential consumer confusion. At least one and possibly two health insurance carriers supported continuing their sale.
- Continuing to allow non-ACA plans risks undermining the individual market risk pool and stability of premium rates for plans offered through the state health insurance exchange. Getting individuals currently insured outside the exchange into exchange plans was a priority.
- The Colorado Division of Insurance and Governor's office will decide whether to allow the sale of non-ACA compliant health plans beyond 2014. A decision has not yet been made and may require legislative action.
- Stakeholders expressed differing views on whether non-ACA plans should be allowed to be sold. Consumer advocacy groups opposed the idea due to potential consumer confusion. At least one and possibly two health insurance carriers supported continuing their sale.
- Continuing to allow non-ACA plans risks undermining the individual market risk pool and stability of premium rates for plans offered through the state health insurance exchange. Getting individuals currently insured outside the exchange into exchange plans was a priority.
- The Colorado Division of Insurance and Governor's office will decide whether to allow the sale of non-ACA compliant health plans beyond 2014. A decision has not yet been made and may require legislative action.
- Stakeholders expressed differing views on whether non-ACA plans should be allowed to be sold. Consumer advocacy groups opposed the idea due to potential consumer confusion. At least one and possibly two health insurance carriers supported continuing their sale.
- Continuing to allow non-ACA plans risks undermining the individual market risk pool and stability of premium rates for plans offered through the state health insurance exchange. Getting individuals currently insured outside the exchange into exchange plans was a priority.
https://mail.google.com/mail/u/0/?ui=2&ik=e13dc557e6&view=pt&cat=CORA%20Kane%206-3-14&search=cat&th=1450151b9c95197a&siml=1450151b9c95197 1/5 Salazar - DORA, Marguerite <marguerite.salazar@state.co.us> RE: Notes 4 messages Michele L Patarino <mlpatarino@msn.com> Wed, Mar 26, 2014 at 8:14 PM To: "Brown - DORA, Peg" <peg.brown@state.co.us> Cc: Patty Fontneau <PFontneau@cohbe.org>, Marguerite Salazar <marguerite.salazar@state.co.us> Hi Peg,
Notes below. Ive copied Patty so she can let us know if I got any of this wrong. The presentation that we walked through is also attached if you havent seen it.
DOI and Governors office will make decision about sale of non-ACA compliant plans similar to how they handled EHB; no decisions have been made yet o No specific timeframe was given, but Commissioner Salazar made it clear that allowing sale of non-ACA plans would require legislative action Stakeholder meeting included Patty and Lindy on the phone, but they missed part of the discussion o CCHI submitted a letter to the Commissioner opposing (thought it would create confusion for consumers) the sale of non-ACA plans o CCLP did also (?) One insurance company expressed support for sale of non-ACA compliant plans (Marc Reece corrected this later and said there were two carriers that have now expressed support United plus a plan that only sells in the individual market) o CAHP submitted a letter to the Commissioner and has copied Patty/Policy & Reg Committee (no official position as an organization) C4HCO cares about this decision and needs to express concerns o Rates for 2015 plans are under development now o There is significant value to having the lives that are currently in non-ACA/non- Exchange plans join the pool o Uncertainty leads to higher rates Framework for letter from C4HCO would include: we want the lives that are currently in non-ACA plans to be in the Exchange in 2015 o Sale of non-ACA plans has an obvious impact on enrollment. The individual market in Colorado is 400,000 people, and 90,000 of those are in the Exchange. We want the rest of 6/6/2014 State.co.us Executive Branch Mail - RE: Notes https://mail.google.com/mail/u/0/?ui=2&ik=e13dc557e6&view=pt&cat=CORA%20Kane%206-3-14&search=cat&th=1450151b9c95197a&siml=1450151b9c95197 2/5 them to at least consider the marketplace. o Health plan rates have to be actuarially sound. The individuals who are currently insured but not in the Exchange have passed underwriting; the sooner you get them in the pool, the sooner you stabilize it. o Carriers can no longer say no to individuals; this can lead to adverse selection, especially for smaller plans/new entrants. This impacts their ability to survive. o One of the original principles for the Exchange was to have the same rules inside and outside the marketplace. The board will vote on the letter next week (Tuesday morning April 1). Gretchen will work with staff to draft it. If approved, it will go to the Governor, Barbara, and the Commissioner. Steve ErkenBrack offered one additional detail that having current non-ACA lives (individuals) in the Exchange should include giving them a reasonable time for open enrollment/an orderly transition o Most of the current non-ACA compliant consumers will have coverage ending 11/30/2014 o They will have to purchase 2014 plans for one month to have coverage starting 12/1/2014 o Then they will buy 2015 plans this could be confusing/difficult/a barrier for participating in the Exchange o Could the DOI allow the plans to extend to the end of 2014 so consumers can purchase 2015 plans? Would this be a fourth option (status quo, allow continued sale for 1 year, allow continued sale for 2 years, allow extension only to the end of 2014) At the end of the discussion (and literally right before you joined the call, Peg), there was discussion about whether the points above apply to individual and small group or just individual o Marc Reece noted that the small group market is already guaranteed issue, so the implications are somewhat different o However, the overall theme that having more lives in the small group/SHOP market will improve efficiency and administration is correct
Patty, if you have anything to add, feel free. Peg, if it would be easier to chat about this, let me know. MP
Michele L Patarino Consultant, Collaborative Health Solutions 303.763.7597 office 303.522.3980 cell 6/6/2014 State.co.us Executive Branch Mail - RE: Notes https://mail.google.com/mail/u/0/?ui=2&ik=e13dc557e6&view=pt&cat=CORA%20Kane%206-3-14&search=cat&th=1450151b9c95197a&siml=1450151b9c95197 3/5
From: Brown - DORA, Peg [mailto:peg.brown@state.co.us] Sent: Wednesday, March 26, 2014 4:04 PM To: Michele Subject: Re: Notes
Thanks.
Peg Peg Brown Deputy Commissioner Colorado Department of Regulatory Agencies Division of Insurance 1560 Broadway, Suite 850 Denver, CO 80202 P 303.894.7501 | F 303.894.7455
PLEASE NOTE: My e-mail address has changed to Peg.Brown@state.co.us
CONFIDENTIALITY NOTICE: This message is intended only for the use of the individual to whom it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you are not an intended recipient you are not authorized to disseminate, distribute or copy this e-mail. Please notify the sender immediately if you have received this e-mail by mistake and delete this e-mail and any attachments from your system.
On Wed, Mar 26, 2014 at 4:00 PM, Michele <mlpatarino@msn.com> wrote: Peg, I have one more MTG then will send you a summary of the discussion. 6/6/2014 State.co.us Executive Branch Mail - RE: Notes https://mail.google.com/mail/u/0/?ui=2&ik=e13dc557e6&view=pt&cat=CORA%20Kane%206-3-14&search=cat&th=1450151b9c95197a&siml=1450151b9c95197 4/5 MP
20140326-Policy-Regualtions-Committee-Presentation.pdf 1016K Patty Fontneau <PFontneau@connectforhealthco.com> Wed, Mar 26, 2014 at 8:23 PM To: Michele L Patarino <mlpatarino@msn.com> Cc: "Brown - DORA, Peg" <peg.brown@state.co.us>, Marguerite Salazar <marguerite.salazar@state.co.us> Thanks Michele. Two small clarifications: 1. we believe it's the DOI's decision, and that they would work with the Gov's office. 2. One carrier was shop specific and the other carrier only had individual plans in the marketplace. Patty Fontneau CEO Connect for Health Colorado pfontneau@connectforhealthco.com 720-496-2555 (office) 303-870-5832 (cell) [Quoted text hi dden] [Quoted text hi dden] PLEASE NOTE: My e-mail address has changed to Peg.Brown@state.co.us<mailto: Peg.Brown@state.co.us> [http://www.dora.state.co.us/images/Service_Mark.jpg] CONFIDENTIALITY NOTICE: This message is intended only for the use of the individual to whom it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you are not an intended recipient you are not authorized to disseminate, distribute or copy this e-mail. Please notify the sender immediately if you have received this e-mail by mistake and delete this e-mail and any attachments from your system. On Wed, Mar 26, 2014 at 4:00 PM, Michele <mlpatarino@msn.com<mailto: mlpatarino@msn.com>> wrote: Peg, I have one more MTG then will send you a summary of the discussion. MP <20140326-Policy-Regualtions-Committee-Presentation.pdf> Salazar - DORA, Marguerite <marguerite.salazar@state.co.us> Wed, Mar 26, 2014 at 8:36 PM To: Michele L Patarino <mlpatarino@msn.com> Cc: "Brown - DORA, Peg" <peg.brown@state.co.us>, Patty Fontneau <PFontneau@cohbe.org> Thanks Michelle. One important clarification is that the non compliant plans expire on 12/31/14, not 11/30/14. We made that a requirement last year. Marguerite [Quoted text hi dden] 6/6/2014 State.co.us Executive Branch Mail - RE: Notes https://mail.google.com/mail/u/0/?ui=2&ik=e13dc557e6&view=pt&cat=CORA%20Kane%206-3-14&search=cat&th=1450151b9c95197a&siml=1450151b9c95197 5/5 -- Marguerite Salazar Insurance Commissioner Colorado Department of Regulatory Agencies Division of Insurance, Commissioner's Office 1560 Broadway, Suite 850 Denver, CO 80202 P 303.894.7425 | F 303.894.7455 Marguerite.salazar@state.co.us Patty Fontneau <PFontneau@connectforhealthco.com> Thu, Mar 27, 2014 at 7:27 AM To: "Salazar - DORA, Marguerite" <marguerite.salazar@state.co.us> Cc: Michele L Patarino <mlpatarino@msn.com>, "Brown - DORA, Peg" <peg.brown@state.co.us> That's great!! We didn't know that. Wonderful news. Patty Fontneau CEO Connect for Health Colorado pfontneau@connectforhealthco.com 720-496-2555 (office) 303-870-5832 (cell) [Quoted text hi dden]