AFFORDABLE HEALTH CARE ACT - GLASS calls on Commissioner Nickel for Status Report on Wisconsin

MILWAUKEE (MPA-PPR) - October 4, 2012, Mary Glass, Chair/CEO, Milwaukee Professionals Association, has contacted both the Wisconsin Office of Commissioner of Insurance Ted Nickel and Secretary Kathleen Sebelius, USGov Health and Human Services for transparency in the implementation of the Affordable Health Care Act in Wisconsin.

On September 28, 2012, Commissioner Nickel submitted correspondence to Secretary Sebelius and voiced his office lack of readiness due to federal regulations that had not been received to complete the EHB/Essential Health Benefit Benchmark Plan due by September 30, 2012 for implementation of the Affordable Health Care
Act law.
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Full implementation of the Affordable Health Care Act is January 1, 2014.  There are a number of action steps necessary for to be an Exchange.  The Exchange is the place for which the public would receive implementation, monitoring/oversight and administration of "insurance"services.  The federal government office for implementation is the US Government Department of Health and Human Services.

Types of Exchanges

• state exchange - operated by the state
• federal-facilitated exchange - operated by the federal government
• partner exchange - operate by the state and federal government

The state has first option of operation of an Exchange.  If a state chooses not to operate, the federal government must provide the services of an Exchange.  Federal government operate Exchange; state makes key decisions, does plan management and some consumer assistance.

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Deadlines - Timeline

• September 30, 2012 - Essential Health Benchmark
• November 16, 2012 - Applications Due
• January 2013 - HHS Certifies State Exchanges
• October 2013 - Initial Open Enrollment Period
• January 2014 - Exchange Coverage Effective
• Establishment Grants - Available through 2012

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Commissioner Ted Nickel

After reading Commissioner Nickel's letter to Secretary Kathleen Sebelius, I felt it was important to contact Commissioner Nickel's office for further insight.  Yes.  We get the lack of federal regs are needed for certain portions of the Essential Health Benefit Benchmark Plan.  However, there is much that can and should be taking place in to develop the inside and outside insurance market.  There are additional operational and administrative steps that can and should be in-process and/or completed, said Glass.

The specific questions for Commissioner Nickel's office were/are:

1. Affordable Health Care Act federal law will preempt any state law.  However, for edification, do we have a Wisconsin law that prevents the implementation of the Affordable Health Care federal law?  If so, what is the statute?
2.  What have you in place for those folk 100%-400% below poverty?
3. What about the subsidies?
4. What exactly have you done regarding “market reforms” – Inside market and outside markets?
5.  What has your office provided for the insurances for product development?  Since they must be able to share with the public by the last quarter of 2013.
6.  What about the guarantee issues? 
7.  What about the rating reform – no annual or lifetime limits?
8.  Benefits package in the individual markets - What about the actual value for metal levels – bronze, silver, gold, platinum and catastrophic plan?  Where exactly are we with that?  What is your final position regarding the study and its findings
9. What about the 3-year reinsurance windfall (billions of $$$) – shifted down to individual market?  Who are the following:
   
   
   o   3 largest federal employee groups
   o   3 largest state employee groups
   o   3 smallest group
   o   largest HMO
10. What’s the criteria for selection of the group for reinsurance? 
11. What about the “Open Enrollment” in both the inside and outsidemarket?  We are about to enter Open Enrollment per annual process for individual role does the public play in the selection of the group?
12. What about the Medicare options – EXPANSION (133% of poverty)
13. What role does the PUBLIC play in the selection of the group?
14.  What’s the criteria for selection of the group for reinsurance? 
15. What about the “Open Enrollment” in both the inside and outsidemarket?  We are about to enter Open Enrollment per annual process for individual role does the public play in the selection of the group?
16. What about the Medicare options – EXPANSION (133% of poverty)?
17. What has your office done in this area for the policies regarding security and privacy that are compatible with HIPAA/The Health Insurance Portability and Accountability Act (HIPAA)? 

    
    

    Are there Wisconsin state-mandated security and privacy guidelines?

What role has/WILL the PUBLIC play in the selection of the group?

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The seventeen (17) questions to Commissioner Nickel provides a framework and strong foundation for successful implementation in the state of Wisconsin.

"In addition to telephone calls to Washington, DC, Baltimore, MD and Beverly Hills, CA, Glass's office is in the process of gathering information for a more detailed letter to Secretary Sebelius that includes concerns for the lack of regulations; and, how this could be used as an excuse of moving forward for the state of Wisconsin - either way, the residential and business stakeholder are at risk, said Glass.