The Tyranny of Plan Choice - Health Connector Board Meeting Report
To kick off yesterday’s Connector Board meeting, EOHHS Secretary and Connector Board Chair Marylou Sudders introduced two new Connector Board members appointed by Governor Baker. Mark Gaunya replaces George Gonser as the broker representative, while Rina Vertes replaces John Bertko as the actuary representative. Sudders said that the two additional open board positions – the economist and small business representative – will be announced in April.
Louis Gutierrez, the new Executive Director for the Health Connector, shared non-group health and dental plan enrollment numbers. As of March 1st, 124,215 people are enrolled in health coverage aand the Connector continues to see enrollment for April 1st.
Total enrollment thus far includes:
- 128,000 non-group health plan enrollees, including 91,000 with subsidized coverage
- 31,104 non-group dental enrollees
- 479 (109 groups) small group dental enrollees
- 4,248 (901 groups) small group health plan enrollees
Gutierrez pointed out the significant and growing interest in dental coverage. He also said that the Connector will continue to study how members transitioned and why people did or did not move into new coverage through MassHealth or the Health Connector.
Lastly, Gutierrez announced two new staff:
- Vicki Coates will start as the Connector’s Chief Operations Officer on March 16th
- Patricia Wada who replaced Maydad Cohen as the Special Assistant to the Governor for Project Delivery on the Health Insurance Exchange (HIX) project.
Materials from the meeting are here, and our full report is coming up after the break .
Calendar Year 2015 & 2016 Affordability Schedules
At the February meeting, the Connector Board voted to release the proposed 2015 and 2016 Affordability Schedules for public comment. As a refresher, the Affordability Schedule determines what is considered affordable for purposes of enforcing the state individual mandate, which requires adults to purchase health insurance if it is affordable to them.
The proposal converts the state Affordability Schedule from a flat premium dollar amount to an entirely percentage-based standard and maintains progressivity for people at or below 300% of the federal poverty level (FPL). For people between 300-400% FPL, the new percentages reflect the average percentage of income reflected by dollar amounts in previous schedules, to be adjusted in 2016 to maintain progressivity throughout the schedule. The proposed Affordability Schedule for residents with incomes above 400% FPL aligns with the federal standard – 8.05% in 2015 and 8.13% in 2016.
As with the past several years, our very own ACT!! Coalition was the only entity to submit comments. Overall, the ACT!! Coalition appreciates that the Connector maintained progressivity in the schedule. Changes suggested by the ACT!! Coalition include:
- Taking a more gradual approach to implementing a percentage-based schedule for people with incomes below 300% FPL;
- Consider out-of-pocket costs in the affordability standard; and
- Modify certain non-coverage or affordability state individual mandate processes to align with federal processes.
Board member Nancy Turnbull highlighted the ACT!! Coalition’s comment about considering out-of-pocket costs. She cited a recently released Kaiser Family Foundation report showing that many individuals and families do not have enough assets to afford even moderate deductibles.
The Connector Board voted to adopt the 2015 and 2016 Affordability Schedules as proposed by staff at the February 12th Board meeting.
2016 Qualified Health Plan & Dental Plan Seal of Approval
The Connector Board began conversations on the Connector’s Seal of Approval (SoA) process for 2016. Through this process, the Connector decides which medical and dental plans to offer. Connector staff outlined goals for the 2016 SoA, including reducing administrative burden, simplifying plan choice, and cost-containment in the ConnectorCare program.
Today, the Health Connector offers 126 Qualified Health Plans (QHPs) from 11 carriers, comprising standardized and non-standardized plans on various networks. For 2016, Health Connector staff propose the following changes:
- Eliminating two of the previously required standardized plans (one Gold, one Platinum);
- De-standardizing Bronze tier plans;
- Placing a cap of 14 plans a single carrier may offer;
- Lifting restrictions on the type of cost-sharing that may be included in “wrap” (ConnectorCare)-compatible plans.
On the Qualified Dental Plan (QDP) side, currently, 5 carriers offer 24 plans – 19 standardized and 5 non-standardized – in the non-group and small group markets through the Health Connector (only 2 carriers offer plans in the non-group market). For 2016, Health Connector staff propose requiring carriers to offer 3 standardized plans – 1 pediatric, 1 “high”, and 1 “low” dental plan and placing a cap of 3 non-standardized plans each carrier may offer.
In addition, the Health Connector proposes adding key certification criteria across QHPs and QDPs:
- Inclusion of 20% of Essential Community Providers in the plan network;
- Fulfillment of federal requirements for Quality Improvement Survey work; and
- Compliance with CMS enrollee satisfaction survey and quality reporting requirements.
Board member Dolores Mitchell commented that the Connector should re-examine the balance between choice and excessive choice. Nancy Turnbull agreed, adding that the proposed 2016 SoA requirements are a step in the right direction, but that the Connector has a long way to go to simplifying plan choice. She stated that what consumers think is most important, and the first step in simplification should be market research and a consumer survey – the voice of consumers is essential to making the best decisions. Board member Lou Malzone reiterated his oft-heard mantra around too much plan choice and expressed interest in continuing this conversation in earnest.
Celia Wcislo agreed with both Mitchell and Turnbull’s comments and added that one of the things that complicated consumers’ experience this year is the lack of an integrated provider search – so that people know what they are buying – and a clunky premium payment system. Louis Gutierrez agreed that tackling the provider search and payment functions of the website are on the priority list. He is not sure whether the provider search will be up and running for the next open enrollment period, but committed to at least posting plan information more consistently. Gutierrez and the Connector staff are also looking into a payment system to replace the current one and improve the consumer experience.
Dolores Mitchell asked Connector staff whether they have done a (subjective) analysis about why people chose which plans. Ashley Hague, Deputy Director for the Health Connector, responded that in her experience helping consumers one-on-one during this past open enrollment period, people look at premium cost, then the deductible and then whether their providers are included in the plan. Mark Gaunya, the newly-appointed broker representative on the Connector Board, said that in his experience, the first thing people ask about a plan is whether their provider is included, then they look at premium and out-of-pocket costs.
Wcislo inquired as to whether the Health Connector is required to offer Bronze plans under the Affordable Care Act (ACA). Hague responded that the Connector is not required to offer Bronze plans and potentially has the flexibility to not accept Bronze plans. QHPs are only required to offer Silver and Gold plans. However, eliminating Bronze plans from the Health Connector would contradict the state’s Minimum Creditable Coverage (MCC) standards, which make reference to Bronze plans.
On the dental side, Turnbull commented that the Connector should re-examine the policy of not requiring inclusion of pediatric dental benefits in health plans, as not everyone who purchases medical coverage is buying dental coverage; we need to think about the percentage of kids covered through the Health Connector who do not have dental coverage. Connector staff members Sarah Bushold responded that 6,195 children above 400% FPL are enrolled in Health Connector medical coverage; of those, only 1,464 (24%) are also enrolled in a dental plan through the Health Connector.
The Health Connector plans to release the 2016 Seal of Approval RFR by the end of the day tomorrow. Carriers wishing to participate must respond by May 15th.
The next Connector Board meeting is scheduled for Thursday, April 9th at 9:00am, One Ashburton Place, 21st floor, Boston.