The Center for Consumer Information and Insurance Oversight (CCIIO), a division of the Centers for Medicare and Medicaid Services (CMS), recently posted new guidance concerning federally-facilitated and state-based Exchanges (Marketplaces) established under the Affordable Care Act (ACA). The guidance purports that if states do not adhere to and enforce the requisite standards for health insurance issuers in federally-facilitated Exchanges, then CMS intends to coerce enforcement through civil penalties and plan decertification. CMS does not believe that decertification will be a common occurrence. In addition, the guidance stated that qualified health plans (QHP) paired with health savings accounts (HSA) must meet the cost-sharing reduction standards that apply to low income-individuals. CCIIO published additional guidance that expands upon which activities, in both federally-facilitated and state-based Marketplaces, that qualify for grant funding under ACA Section 1311. For instance, state-based Marketplaces are not permitted to use this funding for navigator outreach and education, yet they are allowed to use Section 1311 funds for "in-person assistance programs."

Today, the Centers for Medicare and Medicaid Service (CMS) announced a 3-day extension for insurers submitting a qualified health plan (QHP) on the Federally-Facilitated Exchanges (FFE). Insurers will have until May 3rd at 8:00 pm, after which CMS will provide the opportunity for a 3-day Limited Correction Window. The window will permit insurers to make minor application adjustments deemed appropriate by CMS.

The Centers for Medicare and Medicaid Services (CMS) released a draft letter to issuers regarding Federally-facilitated and State Partnership Exchanges. This guidance letter offers technical and operational guidance that will permit Qualified Health Plan (QHP) issuers to operate successfully in Federally-facilitated Exchanges and Federally-facilitated SHOPs, including State Partnership Exchanges. One specific resource addressing requirements presented in this letter is a database of essential community providers (ECPs). ECPs treat low-income individuals in medically underserved areas. Although non-exhaustive, this database is designed to provide CMS an estimate regarding the number of ECPs in a QHP's service area.