Health Reform WK-EDGE Health insurers given 2020 due dates for certain proposed rate filings
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Tuesday, April 7, 2020

Health insurers given 2020 due dates for certain proposed rate filings

By Cathleen Calhoun, J.D.

Specific summer due dates released for proposed rate filings as well as specific late summer and early fall final rate filing due dates.

CMS has issued a bulletin outlining the submission deadlines for health insurance issuers to submit rate filing justifications for single risk pool coverage in the individual and small group (or merged) markets effective on or after January 1, 2021. The bulletin breaks down the information into rate review timelines: (1) proposed rate filings—issuer submission deadlines; (2) proposed rate filings—postings by CMS; and (3) final rate filings—posting by CMS.

Issuer submission deadlines. Health insurance issuers must submit a proposed Rate Filing Justification to CMS by either June 3, 2020, or July 22, 2020, depending on the status of their state’s Effective Rate Review Program:

  • Due June 3, 2020: Issuers in a state without an Effective Rate Review Program must submit proposed rate filings for all single risk pool coverage, regardless of whether or not the filing contains a Qualified Health Plan (QHP), to CMS. A qualified health plan (QHP) is defined in the Affordable Care Act (ACA) (P.L 111-142) as an insurance plan that is certified by the Health Insurance Marketplace, provides essential health benefits (EHBs), follows established limits on cost sharing, and meets other requirements outlined within the application process.
  • Due July 22, 2020: Issuers in a state with an Effective Rate Review Program must submit proposed rate filings for all single risk pool coverage, regardless of whether or not the filing contains a QHP, to both CMS and the state by a date set by the state, as long as the date is no later than July 22, 2020.

Also, issuers submitting QHP applications to participate in exchanges served by the HealthCare.gov platform must submit their QHP Rates Table Templates by July 22, 2020.

Proposed rate filings. All applicable parts of the Rate Filing Justification for all single risk pool coverage (including both QHPs and non-QHPs) will be posted by CMS, including those products that include a plan with a rate increase that is subject to review. CMS plans to post information on proposed rate filings for consumers to review on July 31, 2020 at https://ratereview.healthcare.gov.

  • Due July 22, 2020: CMS stressed that issuers must complete all changes to proposed rate filings in the Health Insurance Oversight System Unified Rate Review (HIOS URR) module by 3:00 p.m. EDT on July 22, 2020.

Final rate filings. Similar to the proposed rated filings, for all single risk pool coverage (including both QHP and non-QHPs), CMS will post all applicable parts of the Rate Filing Justification for all final rate filings. CMS noted the following due dates:

  • Due August 19, 2020: Issuers in states with exchanges served by the HealthCare.gov platform must finalize all rate filings that contain a QHP in the HIOS URR module by 3:00 p.m. EDT. All issuers must finalize all rate filings that only contain non-QHPs in the HIOS URR module by 3:00 p.m. EDT on October 15, 2020.
  • Due October 15, 2020: Issuers in states with a state-based exchange that does not use the HealthCare.gov platform must submit final rate filings that contain a QHP to both CMS and the state by a date set by the state, so long as the date set by the state is no later than October 15, 2020.

CMS has listed November 2, 2020 as the date it plans to post final rate information for single risk pool coverage (including both QHPs and non-QHPs).

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