As anticipated, the NAIC approved a host of PPACA-related model laws and more at the December 16 conference call held by the Joint Executive/Plenary Committee.
Model language on such reform provisions as preexisting condition exclusions for children under age 19, lifetime and annual limits, rescissions, dependent coverage to age 26 was approved. Standard definitions and standards for the summary of benefits and coverage were sent to HHS for review. And the Rate Filing Disclosure Form that’s already finding its way into state regulations in connection with increases deemed “unreasonable” is now in the hands of HHS for consideration as part of the rate review regulation under development.
Then on Tuesday, December 21, HHS released an early look at the rate review rule, inviting comments to be submitted no later than 60 days after announcement in the Federal Register, expected as early as Thursday, December 23. Intended to work in tandem with the recently-issued Medical Loss Ratio rule, the newly-proposed rate review rule is in furtherance of PPACA’s intent to strengthen state regulation of individual and small group rates and provides that “the rate review process established in the proposed regulation would begin implementation with rate increases filed in a State on or after July 1, 2011, or effective on or after July 1, 2011 in a State that does not require rate increases to be filed…” HHS does point out that despite calls for regulation of large group market rating practices, that segment is not addressed in the provisions, while holding open the possibility of further regulation of large group rates in the future. Further comments on this subject are also invited by HHS.
Busy times in Kansas City, Washington … and the North Pole.
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