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Request for Recommendations on Exchange Implementation

Have ideas on how the Exchanges should look? Get your opinion heard!

The federal Department of Health and Human Services has issued a request for comments on implementation of the Exchanges to shape future rulemaking and grant solicitations.  With the help of these comments, HHS will develop standards for the establishment and operation of the Exchanges (the entities through which individuals will purchase health insurance plans and, for some, the gateway through which they will access Medicaid or CHIP).

Here is the official HHS request.

Comments are due on October 4, 2010.

There are more than seventy questions.   Some, such as the status of planning for establishing Exchanges, appear to be primarily directed at states.  Others will be of great interest to consumers and advocates.

Here are some examples:

• What are the major considerations involved in certifying Qualified Health Plans (QHPs) under the Exchanges and what factors should be considered in developing certification criteria?

• What issues need to be considered when establishing appropriate standards for ensuring a sufficient choice of providers and providing information on provider availability?

• What factors are important in establishing minimum requirements for the level of coverage offered through a QHP?

• What factors should Exchanges consider in reviewing justifications for premium increases from insurers seeking certifications as QHPs?

• What factors are most important in establishing plan quality ratings and what are some minimum standards that could be considered when doing so?

• What are some of the key considerations associated with conducting on line enrollment?

• What specific planning steps should the Exchanges undertake to ensure that they are accessible and available to individuals from diverse cultural origins and those with low literacy, disabilities, and limited English proficiency?

• How can eligibility and enrollment be effectively coordinated between Medicaid, CHIP, and Exchanges?

• What are the key considerations related to States using Exchange or Medicaid/CHIP application information to determine eligibility for all three programs?

• What kind of outreach strategies are likely to be most successful in enrolling individuals and how can they be coordinated with efforts for other programs?

• What are some of the best practices in conveying information to consumers relating to health insurance, plan comparison, and eligibility for premium tax credits, or eligibility for other public insurance programs such as Medicaid?

• What are the pros and cons of various options for collecting and reporting Exchange-related complaints (e.g. at federal, state, or Exchange level?).

If you have any thoughts on these or other Exchange-related issues, get your comment together now and make sure to submit it before October 4th.