Marketplace Components FAQ
- Are there a maximum number of plans a carrier may offer on the Marketplace?
No. Issuers may submit as many plans as it wants to offer.
- How often are carriers permitted to put new plans or new pricing on the Marketplace?
Issuers may file new plans and pricing for the Marketplace on an annual basis. Each year a filing window will be established during which new plans and pricing may be filed, along with required binders. New plans for both the Individual and Small Group Marketplace filed within the filing window will have a January 1 effective date for the subsequent year. Individual plan pricing remains as filed for the year. Small Group plans may submit 2nd and/or 3rd/4th quarter adjustments. DIFS issues guidance for quarterly rate changes each year in the “What’s New” section of the DIFS website.
- What method will be used to electronically transmit enrollment, premium payment and payment of subsidies?
CMS determines in the method as required under 45 CFR 155.270.
- What is the deadline to complete the accreditation process for QHP issuers that are not currently accredited?
- During certification for an issuer's initial year of QHP certification (for example, in 2013 for the 2014 coverage year), an issuer without existing accreditation granted by a recognized accrediting entity for the same state in which the issuer is applying to offer coverage must have scheduled or plan to schedule a review of QHP policies and procedures of the applying QHP issuer with a recognized accrediting entity.
- Prior to an issuer's second year and third year of QHP certification (for example, in 2014 for the 2015 coverage year, and 2015 for the 2016 coverage year), an issuer must be accredited by a recognized accrediting entity on the policies and procedures that are applicable to their Marketplace products, or an issuer must have commercial or Medicaid health plan accreditation granted by a recognized accrediting entity for the same state in which the issuer is offering Marketplace coverage and the administrative policies and procedures underlying that accreditation must be the same or similar to the administrative policies and procedures used in connection with the QHP.
- Prior to the issuer's fourth year of QHP certification and in every subsequent year of certification (for example, in 2016 for the 2017 coverage year and forward), an issuer must be accredited.
For additional information, please review Chapter 2, Section 5 of the 2015 Letter to Issuers in the Federally-facilitated Marketplace (FFM).
- What kind of proof must we require for an individual who is requesting a special enrollment? Do we take them at their word or do they have to show us something?
CMS includes information regarding special enrollment in its annual Notice of Benefit and Payment Parameters.
- Will HMOs still have to provide one open-enrollment period annually?
Yes, the open enrollment period will either be an open enrollment for an individual plan to be offered on or off the Marketplace. If an HMO off the Marketplace decides to limit enrollment to open and specific enrollment periods, the enrollment period must mirror the enrollment period on the Marketplace.
Subsection E, 45 CFR 155.410 and 155.420 explains enrollment in QHPs, a link in provided for your reference: 45 CFR 155.410. For individual QHPs offered through the Marketplace, issuers, including HMOs, must adhere to the initial and annual open enrollment periods as required under 45 CFR 155.410. The initial open enrollment period begins October 1, 2013, and extends through March 31, 2014. For benefit years beginning on or after January 1, 2015, the annual open enrollment period begins October 15 and extends through December 7 of the preceding calendar year. 45 CFR 155.420(d) provides nine events that would trigger eligibility for qualified individuals to enroll in QHPs during a special enrollment period outside of the established annual open enrollment period.
- Does the ACA's, three-month grace period requirement for consumers receiving premium tax credits supersede the state's prompt pay law?
The federal regulation supersedes state law in the above scenario. States can maintain their laws if it does not interfere with the implementation of federal law. In this case, the federal grace period requirement supersedes the state prompt pay law.
- What options is Michigan considering to address adverse selection in the individual market?
Michigan has not taken action specifically related to curtailing adverse selection.
- At what point in the issuer agreement process can an issuer decide which of its certified products will be offered through the Marketplace?
Signing the issuer agreements with CMS will commit the issuer to the Marketplace for those selected products. Up to the time of signing, the issuer can decide whether it wants to market its plans on the Marketplace. The issuer must have indicated, at the time of filing, that the plan was for both on and off the Marketplace.
- Are all certified products required to be offered on the Marketplace?
No, an issuer may decide prior to signing the agreement whether they want to market the plan on the Marketplace. All pediatric dental plans are Marketplace-certified, regardless of the sales market.
- What application form and enrollment process will Michigan use for Marketplace enrollments?
As an FFM state, Michigan will follow the federal guidelines on application and enrollments in the FFM. Please review the document below for further information.
FFM Enrollment Operational Policy & Guidance.
The answers provided are not meant to be a substitute for legal advice.