EHB Is The New MCC
State officials have begun the process of determining which health plan will serve as the essential health benefits (EHB) benchmark plan for Massachusetts. The EHB refers to the set of services that many health plans will be required to cover beginning in 2014 pursuant to §1302 of the Affordable Care Act (ACA). It applies to all non-grandfathered health plans in the individual and small group markets sold both inside and outside of Exchanges, as well as to Medicaid benchmark plans.
Guidance released by the federal Department of Health and Human Services (HHS) in December directs each state to select a benchmark plan that will serve as the reference point for EHBs in that state. The federal Bulletin specifies the following options for selecting a benchmark plan: 1) the largest small group plan in one of the three largest small group products in the state, by enrollment; 2) one of the three largest state employee health plans by enrollment; 3) one of the three largest federal employee health plan options by enrollment; or 4) the largest HMO plan offered in the state’s commercial market by enrollment. While the ACA establishes that the EHB must include benefits for ten broad categories of benefits (including mental health and substance use disorder services, prescription drugs, preventive and wellness services and chronic disease management, and pediatric services, including oral and vision care for children), the guidance leaves states with the discretion to adopt, within certain parameters, their own definition of the EHB.
The Division of Insurance (DOI) recently compiled a comprehensive chart comparing benefit information for ten different plans that may be considered as benchmark plan options for Massachusetts. The chart provides a detailed comparison of hospital, emergency room and ambulatory services. While the DOI has not yet determined the relative value and cost-impact of the plans, this information will also be made available in comparing plans.
Over the next few months, the Insurance Market Reform Work Group, co-chaired by the Health Connector and the DOI, is hosting a series of open meetings to solicit feedback on designating the EHB, the first of which was held on March 9 at the DOI. While the Work Group has outlined some initial questions for stakeholder feedback, the dialogue will be an ongoing process and the group is welcoming written comments as well as feedback during future scheduled meetings.
We appreciate the opportunity for stakeholder feedback throughout the decision-making process and urge the Administration to additionally consider soliciting feedback from the general public in the form of a public hearing shortly after their proposal is released. While most of the differences between the potential benchmark plans are subtle, the selection of an EHB benchmark plan will determine the minimum coverage benefits for all individual and small group plans in Massachusetts and thus will be crucial to ensuring access to comprehensive and robust coverage for thousands of consumers statewide.
-Alyssa Vangeli and Suzanne Curry