Maryland Health Benefit Exchange Web-Based Entities(WBE) Advisory Committee Introductory Meeting July 25, 2013 4:00-6:00 pm UMBC Tech Center 1450 S. Rolling Road, Baltimore, MD, 21229 A service of Maryland Health Benefit Exchange
Agenda Agenda • Introduction of Chair, supporting staff and members ; • Overview; • Description of WBE Advisory Committee charter; • Review of WBE federal regulations and guidance; • Review of MHBE WBE activity to date; • Description of producer authorization; • Update on partnerships in the small group market; • Description of IT system; • Committee discussion; and • Discussion of next meeting. 2
Introductions
WBE Advisory Committee WBE Advisory Committee Members: Dr. Joshua Sharfstein, Chair, MHBE Board of Trustees Jim Bendel, President, Potomac Basin Group Associates Kimberly Cammarata, Director, HEAU John Condrat, Manager, Extend Health Vickie Cosby, Senior Director, Consumer Direct Sales and Training, CareFirst BlueCross Blue Shield Samuel C. Gibbs, III, SVP and President of Government Services, eHealth Mary Lou Fox, Maryland Women’s Coalition for Health Care Reform Melanie C. Green, Health Services Manager, Aetna, Inc. Wesley Mace, Vice President, Kelly & Associates Insurance Group, Inc. Megan Mason, Special Assistant for Health Care Reform, MIA Tara Pellet, Consultant, Allied Resource Management – A TriBridge Partners company Dr. Patrick Richard, Community Alliance For Health Care Coverage & Access 4
WBE Advisory Committee Staff: Frank Kolb, Director of Policy and Government Relations, 410 547-1838 Tequila Terry, Director of Plan and Partner Management, 410 387-3381 Kevin Yang, Chief Information Officer, Jesse Kopelke, Special Assistant to the Executive Director, 410 547-1276 5
Overview of Actions to Date
Board Action to Date Action Since Last Board Meeting: March 12 th : The MHBE Board recommended seeking public comment on the policy, technical and logistical issues of partnering with a WBE. May 14 th : Based on the response to the request for public comment the MHBE Board created the WBE Advisory Committee. July 8 th : The MHBE Board approved members for the WBE Advisory Committee. 7
Description of WBE Advisory Committee Charter
WBE Advisory Committee Charter Purpose: To collect a Maryland-specific perspectives from key stakeholders to inform the Board on whether and how to partner with WBEs as the MHBE moves forward with implementation. These perspectives will help ensure that any partnership enhances Marylanders’ shopping experience while protecting consumers and the integrity of the market. 9
WBE Advisory Committee Charter Objectives: Take testimony from subject matter experts on WBEs; Receive public comment on the key issues around partnering with WBEs; and Facilitate dialogue between members in order to advise the Board on whether and how to partner with WBEs. 10
WBE Advisory Committee Charter The WBE Advisory Committee meetings will adhere to the following framework: Expert and public testimony will be taken on a specific topic; Committee dialogue will be facilitated; MHBE Staff Recommendations will be developed; and MHBE Board will determine next steps. 11
WBE Advisory Committee Charter Topics: Consumer Protection: – Unique WBE consumer protections beyond the minimum requirements set out in the final federal Exchange rule; – Additional WBE services, such as phone support, which would enhance the consumer shopping experience; and – Training standards for WBE producers and non-producer personnel. Contractual Feasibility: – Criteria to determine the number of WBEs participating in the state; – Assessment of the staffing needs of the MHBE in performing WBE oversight and enforcement; – Coordinated enforcement process between relevant state agencies; and – Necessary components of an agreement between a WBE and the MHBE. Technical Feasibility: – Necessary IT testing and integration. 12
Review of WBE Federal Regulations and Guidance
Federal Law The March 2012 federal Exchange rule provides for the use of WBEs: A WBE cannot independently perform eligibility determinations as part of enrollment; and In order to enroll in a QHP, an individual must complete the streamlined application described in 45 CFR § 155.405. 14
Federal Law March 2012 federal Exchange rule provides that a WBE must: Meet all standards for disclosure and display of QHP information; Provide consumers the ability to view all QHPs offered through the Exchange; Not provide financial incentives, such as rebates and giveaways; Display all QHP data provided by the Exchange; Maintain audit trails and records in an electronic format for a minimum of ten years, and Provide consumers with the ability to withdraw from the process and use the Exchange Web site at any time. 45 CFR § 155.220(c)(3) 15
Federal Law On May 1 st CCIIO issued FAQs on the role of agents, brokers and web-brokers in health insurance marketplaces, which indicated: SBEs may work with Web-brokers; and CMS is developing the capability to support integration between a web- broker’s website and the FFE’s website using secure redirect and application programming interface mechanisms. In addition to the minimum requirements set out in the final Exchange rules (45 CFR § 155.220(c)(3)), the FAQs indicated that a web-broker partnering with the FFE must: – Securely transmit and receive QHP, eligibility and enrollment information between the FFE and the web-broker; – Meet all existing and future HHS privacy and security standards; – Authenticate consumer identification; – Comply with State appointment requirements; – Refrain from steering consumers to specific plans; – Disclose compensation; – Offer a QHP shopping experience free of non-QHP advertising; – Provide quality information on each QHP; and 16 – Provide all required disclosures.
Federal Law On June 19 th CCIIO published a program integrity rule, which proposed: To limit a Web- broker’s obligation to disclose and display QHP information to all the information provided by the Exchange or directly by the issuer; In situations where a Web-broker is unable to display certain QHP information, the Web-broker must display a link to the Exchange Website; Web-brokers in the FFE must prominently display language notifying consumers that their Website is not an FFE Website, might not display all QHP data available on the Exchange Website; the Web-broker has entered into an agreement with HHS, and the Web-broker agrees to comply with all federal standards; and Web-brokers who make Websites available to other agents or brokers must require that the agents or brokers using the Web- broker’s Website enter into an agreement with the Web-broker indicating they will comply with federal standards and provide to HHS a list of those agents and brokers. 17
FFE Participation As noted in CCIIO’s FAQs, WBEs will be permitted to partner with FFEs: CCIIO circulated a proposed WBE agreement and the final version will soon be published. Primary areas of the agreement included: – Privacy and security standards regarding Personally Identifiable Information; – An expansive list of services to be provided by the WBE; and – Strict termination procedures, including a “Habitual Default" default provision. 18
Review of MHBE WBE Activity to Date
Request for Public Information Action to Date: March 12 th : The MHBE Board recommended seeking public comment on the policy, technical and logistical issues of partnering with a WBE. March 16 th : A request for public information (RFI) was posted on the MHBE website soliciting public comment on WBEs in the areas of: – Policy (Consumer Value and Protections); – Technology (Access to Maryland Health Connection); and – Logistics (Participation and Enforcement). March 29 th : The RFI comment period closed and the MHBE received comments from 37 individuals representing 41 different interest and organizations. 20
Public Comments Comments provided numerous suggestions, including: Additional consumer protections; Licensure and training requirements; Levels of technical integration; Number of suggested WBE partners; Possible enforcement frameworks; and Potential contractual provisions. 21
WBE Letter of Intent June 11 th -July 1 st MHBE Sought Letters of Intent from Entities Interested in Partnering with the State as WBE: MHBE received responses from eighteen different organizations, including: – Several nationally based WBEs; – A TPA; – A Wholesale distributor; – Several brokerage firms; – An individual producer; – A Non-profit organization; – Several IT companies; and – An independent contractor. Each category of organization had varying degrees of experience and sophistication in providing web-based services. 22
Producer Authorization Process July 25, 2013 A service of Maryland Health Benefit Exchange
Today’s Agenda Producer Operations Guiding Principles Maryland Health Connection – Individuals & Families – SHOP Producer Authorization – Requirements to Apply – Authorization Application – Required Training – Authorization Notification – Authorization Expiration Topics Under Discussion Ways to Get More Information
Producer Operations – Guiding Principles
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