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July/August 2015 St@teside

The Latest from the Federal Government

While many of us have gotten back to the normal daily grind in the wake of the King vs. Burwell ruling and are taking advantage of the time left in the summer before gearing up for 2016 open enrollment period, the federal government has been churning out a variety of updates, guidance, and other resources related to health insurance marketplaces and Medicaid programs. Below is an overview of the latest releases.

Special Enrollment Period for Victims of Domestic Abuse and Spousal Abandonment
On July 27, 2015, the Centers for Medicare and Medicaid Services (CMS) announced that it will now provide a permanent special enrollment period for any members of a household who are victims of domestic abuse or spousal abandonment to obtain coverage through the Federally-facilitated Marketplace (FFM). This guidance also allows State-based Marketplaces to establish similar special enrollment periods.

Renewal and Discontinuation Notices Guidance for 2016
In this guidance, CMS details its plan to continue to waive enforcement of the requirement that insurers give 90-day notice before discontinuing non-grandfathered, non-transitional plans for 2016 coverage. The deadline for insurers to finalize their qualified health plan offerings is in October 2015, which, if the 90-day discontinuation noticing was enforced, would potentially lead to consumers receiving discontinuation notices before they are able to shop for new coverage for 2016. This guidance also states that CMS intends to use the 2015 Federal standard notices for product discontinuations and renewals for the upcoming coverage year.

Fast Track Review Process for Section 1115 Waiver Extensions
In an effort to make the process more efficient and to reduce the administrative burden on both states and the federal government, CMS has established a new process for reviewing states’ proposals to extend their Medicaid and Children’s Health Insurance Program Section 1115 waivers. The guidance provides criteria that can qualify states for the fast track review process and outlines the fast track application process.

Extension of Medicaid Cost Allocation Exception for Human Services Programs
In a letter to Medicaid, Children’s Health Insurance Program, and Health and Human Services directors, and State Marketplace CEOs, the U.S. Department of Health and Human Services (HHS) announced a 3-year extension of the exception to the Office of Management and Budget’s (OMB) cost allocation requirements. OMB’s cost allocation provisions typically require a state to allocate the costs for building a shared information technology system across all benefitting programs. However, the exception allows states to leverage the funding for developing health insurance marketplace and Medicaid eligibility determination systems and build in functionality for human services programs, such as TANF and SNAP, without allocating costs to those programs.

Federal Resources on Section 1332 Waivers
The Center for Consumer Information and Insurance Oversight has created a centralized webpage to house its resources on Section 1332 Waivers, also known as State Innovation Waivers. The webpage currently contains the guidance released to date, fact sheets, and FAQs. For more information on Section 1332 waivers, check-out this blogpost.