For plan administrators, insurers, departments of insurance, and others, anticipating all the rules that may guide the implementation of the Patient Protection and Affordable Care Act has got to be truly daunting at times. But despite what New Age gurus may suggest, dwelling totally “in the present” often doesn’t lend itself to real world developments and their consequences (this is why we have 401Ks, for example).
I recently spent some time just thinking ahead to how 43 U.S.C. s 300gg-15, “Development and Utilization of Uniform Explanation of Coverage Documents; Standardized Definitions,” from HB 3590, a/k/a PPACA, might play out. It reads, in part:
“The standards for the summary of benefits and coverage developed under subsection (a) shall provide for the following:
“(1) Appearance.—The standards shall ensure that the summary of benefits and coverage is presented in a uniform format that does not exceed 4 pages in length and does not include print smaller than 12-point font.
“(2) Language.—The standards shall ensure that the summary is presented in a culturally and linguistically appropriate manner and utilizes terminology understandable by the average plan enrollee.”
Questions about what “culturally and linguistically appropriate” would actually involve once the promised standards (due by next March, with implementation required by March 2012) are issued flooded my brain. Visions of things like minimum Flesch score requirements and formatting changes in rules, checklists, readability certifications, and of course, those pesky “summary of benefits and coverage” documents themselves, passed before my eyes in a frightening, continuous loop. Lots and lots of busy work ahead, potentially, for all concerned.
Then the prospect of increased rate reviews occurred to me, and a friend sent me this AHIP chart. At a time when insurers and insurance departments are already operating with smaller staffs, furloughs, and other budget-induced constraints, the attendant administrative burdens connected to PPACA can appear formidable. Suddenly I was tempted to stop reading tea leaves and simply head straight for a beach. That said, while the phrase “live for today” may have woven itself into our culture (particularly in popular music), where PPACA is concerned, the tune I just can’t get out of my head these days is more like Fleetwood Mac’s “Don’t Stop Thinkin’ About Tomorrow.”
