MINNESOTA COUNCIL of H E A L TH P L A N S

December 6, 2013

COURT INTERNATIONAL BUILDING 2550 UNIVERSITY AVENUE WEST SUITE 255 SOUTH ST. PAUL, MINNESOTA 55114 651-645-0099 FAX 651-645-0098

Delivered via email

April Todd-Malmlov, MNsure Commissioner Lucinda Jesson, Minnesota Department of Human Services RE: MNsure Enrollment Issues Dear Ms. Todd-Malmlov and Commissioner Jesson: I received a copy of a December 4, 2013, letter to Senators Nienow and Benson and Representatives Mack and Hoppe answering questions raised in their November letter to MNsure. I am writing to provide information from the health plans regarding the questions raised in the letter to MNsure which I believe more completely answers questions raised by the legislators. I want to preface my comments by stating that our first priority continues to be for Minnesotans to receive their new enrollment information in a timely fashion and avoid confusion or delays in benefit coverage or obtaining care beginning on January 1. The information in the December 4th letter regarding Medical Assistance and MinnesotaCare is accurate based on the communications we have had with the Department of Human Services (DHS). Earlier this week, Assistant Commissioner Leitz provided an update and details on questions the health plans had raised regarding these two programs. We understand that because critical data interfaces are not yet working, many new enrollees will not have the opportunity to choose their health plans for a month or two. In the meantime, most new Medicaid enrollees will default to fee-for-service while most new MinnesotaCare enrollees will be assigned a health plan according to a DHS formula. We appreciate the information that DHS has provided the health plans. Work remains in order to provide those same reassurances to those in commercial population enrolling through MNsure. While MNsure has sent 834 enrollment data files to health plans for some people who applied on MNsure October 1 through November 24, those data files have errors and are not complete. MNsure’s effort to supplement the 834s with an additional file has revealed inconsistencies between the two files, (i.e. number of enrollees in two files should match and did not or the addresses in the two files should match and did not) therefore health plan companies must employ labor intensive manual processes in order to begin the enrollment process. While MNsure works to correct the supplemental files, other issues have been left to the health plan companies to resolve.

Blue Cross and Blue Shield/Blue Plus of Minnesota  HealthPartners  Medica Metropolitan Health Plan  PreferredOne  Sanford Health Plan of Minnesota  UCare

Page 2 December 6, 2013 April Todd-Malmlov and Commissioner Lucinda Jesson For example:  Duplicate enrollments. Example 1: Jane Doe has two or three records. She has chosen the same product two or three times so her intent appears clear. The health plan must then select which record to use. Example 2: John Smith has multiple records and the records do not match. He has selected two different silver plans and one gold plan. MNsure has told the health plans it would be most expedient for representatives of the health plan company to contact the enrollee to determine the individual’s intent. Once the health plan determines which enrollment record to use, it must alert MNsure of the decisi on so MNsure’s records reflect actual enrollment. This is very time and resource intensive and cannot be sustained as enrollment grows. It also puts the health plans in the position of appearing to be the source of inaccurate or incomplete data. Missing information. Addresses are incomplete, including apartment numbers that are needed to send invoices and enrollment materials. Middle initials are missing. Identification numbers for dependents are missing information. Incorrect information. Some child-only policies appear to have dependents listed. Lack of time for consumer to make premium payments. In the normal course of business, consumers have 30 days to pay an invoice. The lack of timely information from MNsure has resulted in people having very few days to make the payments. If an individual has applied in good faith and received notice from MNsure that they have coverage, MNsure should stand behind its notification.

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The health plans’ most significant concern is that the problems with the timely, complete and accurate transfer of information from MNsure to the health plans will result in consumers not having coverage on January 1, 2014. We continue our work with MNsure to develop contingency plans so that MNsure and health plan companies do not find themselves in the situation of not being able to guarantee that people who believe they have purchased coverage will actually be covered January 1. We believe that MNsure is in the best position to communicate with enrollees since, at this late date, the health plan companies do not have most of the names or information on individuals who have enrolled through MNsure. As you know, we have provided specific recommendations in the past which we continue to believe have the potential to improve the timeliness and accuracy of the enrollment process and provide assurances to consumers that they will have the coverage they believe they have purchased.

Page 3 December 6, 2013 April Todd-Malmlov and Commissioner Lucinda Jesson I hope that this letter clarifies the concerns we continue to have and provides you greater context on the current status of MNsure enrollment implementation. Rest assured we remain committed to working through these issues with you as quickly as possible to ensure consumers’ access to care beginning January1. Very truly,

Julie Brunner Executive Director

cc: Sen. Sean Nienow Sen. Michelle Benson Rep. Joe Hoppe Rep. Tara Mack Brian Beutner MNsure Board of Directors