In a letter to CMS, the American Hospital Association supported the proposed rule for the mitigation of health plan risk due to major changes in insurance rules, but the AHA asked that the rule and its methodologies be more specific and transparent.
The proposed rules would establish a temporary state-based reinsurance program, a temporary federal risk corridor program that would protect health plans against inaccurate rate setting and a permanent state-based risk adjustment program.
The AHA made three recommendations on the proposed rule:
• For each of the three risk mitigation programs, all notices regarding methodologies should be made public with a sufficient period of time allowed for review and comment.
• Health plans should be prohibited from passing on to providers the losses from pro rata reduced payments when the reinsurance program in inadequately funded. The AHA said a pro rata approach could put pressure on health plans to recoup losses from providers treating high-cost cases.
• States should comply with federal regulations when collecting encounter-level data.
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The proposed rules would establish a temporary state-based reinsurance program, a temporary federal risk corridor program that would protect health plans against inaccurate rate setting and a permanent state-based risk adjustment program.
The AHA made three recommendations on the proposed rule:
• For each of the three risk mitigation programs, all notices regarding methodologies should be made public with a sufficient period of time allowed for review and comment.
• Health plans should be prohibited from passing on to providers the losses from pro rata reduced payments when the reinsurance program in inadequately funded. The AHA said a pro rata approach could put pressure on health plans to recoup losses from providers treating high-cost cases.
• States should comply with federal regulations when collecting encounter-level data.
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