SERFF is providing training. Please visit www.serff.com/serff_health_insurance_plan_management.htm for more information. Those on the SERFF email list will be notified of the scheduled trainings.
SERFF has added Michigan specifications as requested by DIFS; limited changes were made by Michigan. Each year, DIFS publishes Bulletins for QHP and Stand-Alone Dental filing guidance. Bulletins are posted in the “What’s New” section of the DIFS website.
Yes, as required under Bulletin 2011-14-INS.
No, HHS will not be reviewing and approving plans and rates offered off the exchange whether they are grandfathered or non-grandfathered plans.
Yes, certification of a QHP constitutes certification for participation on the Marketplace. As a Partnership state, Michigan will submit recommendations to HHS regarding QHP certification and recertification; HHS will receive, approve (as appropriate), implement, and oversee a state's certification and recertification recommendations. However, all health plans sold, whether on the Marketplace or off the Marketplace, must be qualified health plans; it is the certification of these plans that make them eligible for the Marketplace. DIFS does not certify off Marketplace products but does review the plans for EHB compliance.
Issuers must access the Health Insurance Oversight System (HIOS) to obtain a HIOS user ID. Issuers will submit everything to DIFS through SERFF for review and approval, DIFS will transmit the approved binders containing required information and data to HHS. DIFS’ annually published ACA and SADP filing bulletins detail where all documents are submitted.
There are HMOs in Michigan that offer only the Medicaid/MiChild products. If one of these HMOs decides to expand their product offering into the commercial-side of the market, there is no carry-over from the Medicaid side of the market. All form, rate, network adequacy filings that would be required of an HMO in the commercial market must be made. In addition, the SERFF binder filings and the templates would be required.
For HMOs in Michigan that offer only Medicaid products and wish to expand into the commercial-side of the market, there are templates that must be completed on the SERFF binder filings, specifically for network adequacy and service area. These are: (1) Michigan Data Template; (2) Essential Community Providers (ECP) Template; and (3) Service Area Template. These items need to be completed to get approval.
The DIFS Michigan Network Data Template [Request Summary] requires an issuer to provide three years of enrollment projections for each county the issuer's QHPs will be offered on the Marketplace. The template is to be completed and included in the company's Binder(s) submission through SERFF. The following is a link to the DIFS web page containing the Michigan Network Data Template and instructions.
DIFS considers it a service area expansion when a Medicaid-only HMO elects to expand its line of business to include offering commercial individual or small group coverage on the Marketplace. As is required for service area expansions, the HMO must submit two years of financial projections, in addition to its three year membership projections. Financial projections should include a balance sheet, income statement, cash flow, and Risk Based Capital (RBC) level. If a HMO with a commercial line of business files an individual and/or group Binder which includes new counties for which DIFS has not granted service area approval, it must submit two years of financial projections in addition to its three year membership projections for those new counties. Financial projections should include a balance sheet, income statement, cash flow, and RBC level. In either scenario, the financial projections are to be submitted in the supporting documentation tab.
MCL 500.3557(e) requires a HMO to file notice with the Director of any significant changes in operations. A HMO with a commercial line of business offering QHPs on the Marketplace would not be considered a significant change in operations. A Medicaid-only HMO expanding to commercial business by offering individual and/or small group on the Marketplace would be considered a significant change in business. DIFS considers the Medicaid-only HMO's filing of certificates of coverage, rates and binders in SERFF as acceptable notification of the HMO's change in operations and compliance with section 3557(e).
HMOs that currently offer Medicaid plans and are expanding product offerings to the commercial market have the same requirements as all HMOs in the commercial market. The filing requirements are located in Bulletin 2014-06-INS and in Chapter 35 in the Insurance Code.
The filing process for grandfathered plans is not affected by the QHP filing process. Grandfathered plans are not eligible to be on the Marketplace.
A complete set of instructions for each Plan Year can be found here. Issuers may also refer to the Plan Management Tab in SERFF.
Yes, attestations must be submitted through SERFF and must be uploaded under the Supporting Documentation tab of the Binder filing.
QHP issuers must complete the attestation on their own behalf. If a third party filer is managing the filing for the issuer, the third party authorized to make the filing may upload the attestation but it is the issuer that must attest to compliance.
