CMS-9895-F 623
● Improved consumer experience and access to accurate insurance information associated with the requirement that all
Exchanges must have a centralized eligibility and enrollment platform
on its website. Although all current Exchanges meet
this requirement, there may be States transitioning to State Exchanges in the future that would not consider operating a
centralized eligibility and enrollment platform in the absence of this finalized amendment. This policy will set a clear
expectation moving forward for all States that intend to establish and operate a State Exchange.
● Increased transparency for agents, brokers, and web-brokers by specifying who will be reviewing their reconsideration
requests.
●
Improved consumer experience on non-Exchange websites by requiring DE entities to implement HealthCare.gov and
State Exchange website display changes that enhance the consumer experience, simplify the plan selection process, and
increase consumer understanding of plan benefits, cost-sharing responsibilities and eligibility for financial assistance.
●
Reduced burdens and barriers to care for applicants as a result of the policy to permit Exchanges to accept incarceration
attestations without further verification.
●
Improved continuity of coverage for enrollees due to the requirement that Exchanges must automatically re-enroll
enrollees in catastrophic coverage into QHP coverage for the coming plan year.
●
Reduced consumer confusion and increased consumer access to assisters as a result of the requirement that State
Exchanges generally must adopt an open enrollment period that begins on November 1 of the calendar year preceding the
benefit year and ends no earlier than January 15 of the applicable benefit year, with the option to extend the open
enrollment period beyond January 15.
●
Reduced consumer confusion and coverage gaps due to the policy to align the effective dates of coverage after selecting
a plan during certain special enrollment periods across all Exchanges.
●
Reduced overlaps in coverage and premium payments for Exchange enrollees who retroactively enroll in Medicare Part
A or B as a result of the policy to permit Exchange enrollees to retroactively terminate Exchange coverage back to the date
in which they retroactively enroll in Medicare Part A or B, but no more than 6 months before the date that retroactive
termination is requested.
●
Reduced costs for States to perform actuarial analyses to confirm compliance of EHB-benchmark plans with scope of
benefit requirements at § 156.111(b)(2).
●
Reduced coverage barriers to expanding access to adult dental benefits, improved State flexibility to add benefits to
improve adult oral health, and promotion of health equity associated with the policy to remove the prohibition on including
routine non-pediatric dental services as an EHB.
●
Increased issuer flexibility in plan design as a result of the finalized exceptions process to allow issuers to offer
additional non-standardized plan options in excess of the limit of two per product network type, metal level, inclusion of
dental and/or vision benefit coverage, and service area, if specified requirements are met.
● Streamlined payments and collections processes and limited administrative burden for operating HHS programs due to
the policy to align netting regulations at § 156.1215 with the policies proposed in the Federal Independent Dispute
Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges proposed rule.
Annualized Monetized ($/year)
● Cost to issuers being audited for high-cost risk pool payments of approximately $25,078 to complete, submit to HHS,
and implement corrective action plans for certain high-cost risk pool audit observations for each benefit year being
audited, if required by HHS.
● One-time cost in PY 2025 to web-brokers operating in State Exchanges of approximately $860,380 due to the policy to
ensure agents, brokers, and web-brokers operating in these State Exchanges are meeting certain requirements applicable in
the FFE and SBE-FPs.
● Costs to States of $2,346,128 associated with the policy that agents, brokers, and web-brokers operating in State
Exchanges meet certain requirements applicable in the FFEs and SBE-FPs.
● Costs to DE entities operating in FFE and SBE-FP States of approximately $240,120 annually beginning in 2025 as a
result of the requirement that DE entities implement and prominently display website changes in a manner that is
consistent with display changes made by HHS to HealthCare.gov by meeting standards communicated and defined by
HHS within a time period set by HHS, unless HHS approves a deviation from those standards.
● Costs to DE entities participating in State Exchanges of approximately $247,359 annually beginning in 2025 associated
with implementing display changes and submitting requests to deviate from the standards defined by the State Exchange.
● Costs to DE entities operating in FFE and SBE-FP States of approximately $5,171 to submit a request to deviate from
the display approach adopted by HealthCare.gov standards defined by HHS annually beginning in 2025.