ACAP Comment Letter on Proposed QHP Application and Rate Review Timeline

ACAP Comment Letter on Proposed QHP Application and Rate Review Timeline. March 7, 2017


March 7, 2017

Samara Lorenz, Director, Oversight Group
Center for Consumer Information and Insurance Oversight
Centers for Medicare & Medicaid Services
Department of Health & Human Services

Submitted electronically via:

Dear Director Lorenz:

The Association for Community Affiliated Plans (ACAP) respectfully submits comments regarding CCIIO’s Draft Bulletin: Revised Timing of Submission and Posting of Rate Filing Justifications for the 2017 Filing Year for Single Risk Pool Coverage; Revised Timing of Submission for Qualified Health Plan Certification Application.

ACAP is an association of 59 not-for-profit and community-based Safety Net Health Plans (SNHPs) located in 28 states. Our member plans provide coverage to more than 17 million individuals enrolled in Medicaid, the Children’s Health Insurance Program (CHIP) and Medicare Special Needs Plans for dually-eligible individuals, including over 600,000 Marketplace enrollees. Nationally, Safety Net Health Plans serve nearly half of all Medicaid managed care enrollees. Seventeen of ACAP’s Safety Net Health Plan members offer qualified health plans (QHPs) in the Marketplaces in 2017.

ACAP is generally supportive of CMS’ proposal to delay the QHP Certification and Rate Review Timelines if the Marketplace Stabilization Proposed Rule is finalized. If the proposed rule is to be finalized, the additional up-front flexibility in timing will be necessary from an operational standpoint. ACAP wishes to note, however, that it will also result in a significant operational burden on issuers given the consolidation of activities after the initial application submission into a much shorter timeframe. ACAP encourages CMS to consider additional safeharbor periods and flexibility for issuers that ultimately may have trouble meeting the compressed deadlines with such short notice.

In addition, ACAP urges CMS’ to move up the release date of the final Risk Adjustment and Reinsurance Summary Report to prior to the initial application submission window. Developing rates for 2018 prior to knowing risk adjustment results for 2016 remains a significant problem for many ACAP member plans. While the Interim Risk Adjustment Report has been helpful for some issuers, the lack of any information in some states limits its utility. At a minimum, issuers need to know the statewide average premiums prior to submitting their initial QHP applications.

ACAP thanks CMS for its willingness to consider the above-mentioned feedback on proposed 2 changes to the timeline. If you have any additional questions or comments, please do not hesitate to contact Heather Foster (202-204-7508 or


/s Margaret A. Murray
Chief Executive Officer

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