ACAP is an association of 57 not-for-profit and community-based Safety Net Health Plans (SNHPs) located in 24 states. Our member plans provide coverage to almost 10 million individuals enrolled in Medicaid, the Children’s Health Insurance Program (CHIP) and Medicare Advantage Special Needs Plans for dually-eligible individuals. Nationally, ACAP plans serve roughly one-third of all Medicaid managed care enrollees. Sixteen ACAP Safety Net Health Plans have offered qualified health plans on health insurance Marketplaces in their respective states.
We are pleased that CMS released this notice, which will support states in implementing an important program that has great potential to provide affordable coverage for low-income individuals. As we mentioned in our November 2013 letter responding to the Basic Health Program proposed rule, we are very supportive of CMS’ efforts regarding the Basic Health Program (BHP). However, we take substantial issue with the Administration’s choice to prohibit states from using BHP trust funds to administer the BHP. Furthermore, we continue to urge the Administration to provide BHP funds to states based on 100 percent of cost-sharing reductions, rather than 95 percent, as outlined in both this and the 2013 draft rule. We will describe our reasoning in depth later in this letter, but in brief, ACAP strongly urges CMS to allow states to use BHP trust funds to administer the BHP and to provide BHP funds equal to 100 percent of cost-sharing reductions.
A summary of ACAP’s comments follows:
ACAP asks CMS to amend the calculation of the rate described on page 77402 to provide state BHP trust funds with 100 percent of cost-sharing reductions.
ACAP requests CMS to ensure that the premium trend factor described on page 77402 to adjust the reference premium be sufficient to offset what are thought to be artificially low qualified health plan premiums in 2014. In addition, ACAP asks that CMS consider using realtime premium data for the BHP program year as soon as it becomes available.
ACAP urges CMS to allow states to choose whether to pool risk between the BHP and the individual Marketplace.
ACAP requests CMS to describe explicitly that caps applied to enrollee repayments at reconciliation will be applied also to the BHP income reconciliation factor.
ACAP strongly urges CMS to allow states to use BHP trust funds to administer the BHP