Transcript THE COMMONWEALTH FUND Essential Health Benefits Under the Affordable Care Act: HHS Guidance and Key Implementation Issues Sara R.

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COMMONWEALTH
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Essential Health Benefits
Under the Affordable Care Act: HHS Guidance and
Key Implementation Issues
Sara R. Collins, Ph.D.
Vice President, Affordable Health Insurance
The Commonwealth Fund
Alliance for Health Reform Briefing on Essential Health
Benefits: Balancing Affordability and Adequacy
Washington, D.C.
February 3, 2012
What are Essential Health Benefits?
Health Plans That Must Offer
Essential Health Benefits
Actuarial Value
(Average % of
costs covered)
Essential Health Benefits Must Include
at a Minimum 10 categories
Exchange, individual and small
group market
Platinum
90%
Gold
80
Silver
70
Bronze
Catastrophic
Medicaid expansion
Basic Health Plan
1.
ambulatory patient services;
2.
emergency services;
3.
hospitalization;
4.
maternity and newborn care;
5.
mental health and substance use disorder services,
including behavioral health treatment;
6.
prescription drugs;
7.
rehabilitative and habilitative services and devices;
8.
laboratory services;
9.
preventive and wellness services and chronic
disease management; and
60
-
94+
87-94
(statute:90+ for
<150%FPL)
10. pediatric services, including oral and vision care.
68 million people are estimated to enroll in plans subject to the EHB provision
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Note: Actuarial values are the average percent of medical costs covered by a health plan.
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Source: Federal poverty levels are for 2012; Commonwealth Fund Health Reform Resource Center: What’s in the Affordable Care
Act? (PL 111-148 and 111-152), http://www.commonwealthfund.org/Health-Reform/Health-Reform-Resource.aspx.
Premium Tax Credits and Cost-Sharing Protections
Under the Affordable Care Act
FPL
Income for a family of
four
Premium
contribution as a
share of income
<133%
<$30,657
2%
(or Medicaid)
133%- 149%
$30,657 - <34,575
3.0%–4.0%
(or Basic Health Plan)
150%–199%
$34,575 - <46,100
4.0%–6.3%
(or Basic Health Plan)
200%–249%
$46,100 - <57,625
6.3%–8.05%
Out of Pocket
limits
Actuarial value:
Silver plan
94%
S: $1,983
F: $3,967
94%
87%
73%
S: $2,975
F: $5,950
250%–299%
$57,625 - <69,150
8.05%–9.5%
70%
300%–399%
$69,150 - <92,200
9.5%
S: $3,967
F: $7,933
70%
400%+
$92,200+
—
S: $5,950
F: $11,900
—
Note: FPL refers to Federal Poverty Level. Actuarial values are the average percent of medical costs covered by a health plan.THE
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Premium and cost-sharing credits are for silver plan.
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Source: Federal poverty levels are for 2012; Commonwealth Fund Health Reform Resource Center: What’s in the Affordable Care
Act? (PL 111-148 and 111-152), http://www.commonwealthfund.org/Health-Reform/Health-Reform-Resource.aspx.
How Does HHS Propose to Define Essential Health Benefits?
•
Rather than defining one standard benefit package for all states, HHS is
proposing that each state select a benchmark plan in their state that covers
all 10 categories
•
States can select a benchmark plan from the any of four options:
– Any of the three largest small-group plans in the state by enrollment;
– Any of the three largest state employee health plans by enrollment;
– Any of the three largest federal employee health benefits program
(FEHBP) plan options by enrollment; or
– The largest insured commercial non-Medicaid HMO plan in the state.
•
Largest small group plan is default option for states that do not select a
benchmark
•
States must add any missing required benefits to benchmark plans
•
This “benchmark” approach is currently used for health plans offered
through Children’s Health Insurance Program (CHIP), some Medicaid
enrollees.
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Will State Benefit Mandates Be Included in Benchmark
Plans?
•
The law requires states to pay for benefits mandated by state law that fall outside of the
10 benefit categories
•
HHS proposes to allow states a transition period 2014-2015 where states with
benchmark plans that include state benefit mandates outside the 10 categories will not
have to pay the cost of the additional benefits
Will Health Plans Be Required to Meet All Provisions in the
Benchmark Plan?
•
HHS proposes that health plans be required to offer benefits that are “substantially
equal” to the benefits of the benchmark plans
•
Plans may adjust services covered and quantitative limits, as long as they continue to
offer coverage for all 10 categories
•
HHS considering whether plan substitutions for the benchmark plan only be allowed
within each of the 10 categories, or if health plans might be permitted to substitute
benefits across the categories, while maintaining actuarial equivalence (plans would be
of the same value in terms of cost protection)
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Key Questions and Implementation Issues
•
•
•
•
Benchmark Plans
– Do small employer plans meet the standard of a “typical employer plan”
envisioned by the statute?
– Do small employer plans generally cover all 10 categories or are some
categories routinely not included?
State Choice of Benchmark Plans
– What are the tradeoffs and considerations in selecting from the four
options?
– Whither state benefit mandates after the two year transition period?
Health Plan Flexibility
– Will benefit substitutions, variation in visit limits, make it difficult for
consumers to compare plans if benefits vary across plans?
Maintaining Premium Affordability and Cost Protection Over Time
– What are risks of rapid premium inflation for the benchmark plans?
– What are the consequences of premium inflation to government,
consumers, employers, viability of exchanges?
– What are options for limiting premium inflation over time?
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