ACA Rule Offers Health Plans Flexibility, but Also Reasons to Worry

by Leslie Small

While the proposed 2020 Notice of Benefit and Payment Parameters (NBPP) for the Affordable Care Act exchanges offers some good news for qualified health plan issuers, health plans "are probably looking more closely at, frankly, some of the things HHS has chosen not to do at the moment but has flagged for future changes," says Chad Brooker, a director of Avalere's policy practice.

For one, the administration says it is seeking comment on the possibility of changing the ACA exchanges' automatic re-enrollment process. If the process does change significantly, some insurers will be more affected than others, Brooker says. "But I think generally speaking, changes to eligibility that could or will likely have an impact on reducing overall enrollment are things that issuers are not going to look kindly upon."

Perhaps the part of the NBPP that drew the most headlines was a proposed change to how the government calculates the premium adjustment percentage. CMS estimates that the change could result in net premium increases of approximately $181 million per year — or 1% of 2018 benefit-year net premiums — for the 2020 through 2023 benefit years. It also predicts a decline in ACA exchange enrollment of about 100,000 people in 2020.

"I can't overstate how concerning it is," says Sabrina Corlette, a research professor at Georgetown University Health Policy Institute's Center on Health Insurance Reforms. Part of what troubles her is the language the administration used to justify the change, which acknowledges that the majority of the 100,000 individuals estimated to drop coverage as a result will likely become uninsured. "And then there's this sort of economist speak about how making people spend more of out-of-pocket for their health care means they're going to use less, and how that's a societal good," she says. "It's sort of like, 'OK, tell us how you really feel.'"

Meanwhile, in what is likely good news for health insurers, the proposed rule includes changes that are meant to help plans steer enrollees to lower-cost prescription drugs — such as allowing issuers to exclude drug manufacturer coupons from counting toward the annual limit on cost-sharing when a medically appropriate generic drug is available. The NBPP also proposes to lower the user fees paid by qualified health plans sold on the federally facilitated exchange and state-based exchanges that use the federal platform.

From Health Plan Weekly