- Are the Prescription Drug, Network ID, Network Adequacy/ECP, Service Area, and Accreditation Templates allowed to have combined market information for dual issuers?
Yes. However, if the templates contain combined information the completed templates must be submitted with the Small Group filing on 4/11/2016 and contain all of the relevant information for the individual filing. Issuers may not change the template unless it is specifically requested by DIFS or CMS.
- Are issuers able to submit separate Prescription Drug, Network ID, Network Adequacy/ECP, Service Area, and Accreditation Templates?
Yes. However, if an issuer does provide separate templates, the items used by both markets must be provided in each market’s templates and be exactly the same. For example, if an issuer’s individual and small group market both use a service area MIS001 then that service area must be exactly the same on both the individual and small group template. Issuers may not change the templates after the initial submission unless requested by DIFS or CMS.
- Are issuers in both individual and small group markets required to include specific rules to individual market products in the Business Rules Template as part of the small group submission?
No. An issuer in both markets may withhold or revise specific rules for individual market products until the May 9 deadline for the individual market. Issuers must at a minimum provide the base rules in row 10 and specific rules for small group products in their small group submission and these items cannot be modified unless required by DIFS.
The answers provided are not meant to be a substitute for legal advice.