ACA Title 1, Sec. 1415. Premium tax credit and cost-sharing reduction payments disregarded for federal and federally-assisted programs: “Bad” – Further erodes individual role. This provision of the ACA smooths the federal and state eligibility process and simplifies the tax treatment of subsidies and cost reduction payments to beneficiaries. However, this overall provision still creates a… Continue Reading ›

ACA Title 1,Sec. 1414. Disclosures to carry out eligibility requirements for certain programs: “Good” – A necessary evil? This provision provides authority for the sharing of IRS individual taxpayer information among exchanges and the federal government for the purposes of determining the eligibility of the individual to receive subsidies, premium tax credits and cost reductions under… Continue Reading ›

ACA Title 1, Sec. 1413. Streamlining of procedures for enrollment through an exchange and state Medicaid, CHIP, and health subsidy programs: “Good” – If it leads to simplification in program administration. This provision again makes sense on the surface. Let’s make the process of matching potential eligibles with the appropriate public program streamlined, but wouldn’t it… Continue Reading ›

ACA Title 1, Sec. 1412. Advance determination and payment of premium tax credits and cost-sharing reductions: “Ugly” – A bureaucratic nightmare. The bureaucratic machinery necessary to provide advance payments to a possible premium tax credit is another example of overkill. What about the old stand-by of providers carrying accounts payable until the individual or family financial… Continue Reading ›

ACA Title 1, Sec. 1411. Procedures for determining eligibility for exchange participation, premium tax credits and reduced cost-sharing, and individual responsibility exemptions: “Bad” – Way too easy to exploit. This section provides the basic rules for the procedures to determine eligibility, level of premium tax credits, level of reduced cost sharing and waiver of individual responsibility… Continue Reading ›

ACA Title 1, Sec. 1402, Reduced cost-sharing for individuals enrolling in qualified health plans: “Ugly” – Removes most user out-of-pocket cost sharing. This section provides a fairly complicated “sliding fee schedule” for removal of out-of-pocket cost sharing for those whose income is up to 4 times the federal poverty limit. Why “4” times? Why not “3”… Continue Reading ›

ACA Title 1, Sec. 1401. Refundable tax credit providing premium assistance for coverage under a qualified health plan: “Bad” – Here again… “overkill.” In my opinion this section creates more bureaucratic machinations that are fundamentally unnecessary. It covers the detailed rules, conditions and details of how tax credits for public premium subsidies will be calculated and… Continue Reading ›

ACA Title 1, Section 1343, Risk adjustment: “Bad” – Further undermines incentives for efficiency. This section provides a relatively easy way to avoid efficient claims administration while at the same time we as a nation are adopting and implementing ICD- 10 CM. This new set of diagnostic and procedural codes will triple to quadruple the… Continue Reading ›

ACA Title 1,Sec. 1342. Establishment of risk corridors for plans in individual and small group markets.: “Bad” – Removes much of the business incentive for efficiency. This provision effectively eliminates any real incentive for efficiency or prudency in the administration of the health insurance plans for the individual and small group markets. The three year ((2014… Continue Reading ›

ACA Title 1, Sec. 1341. Transitional reinsurance program for individual and small group markets in each state: “Bad” – Should be emergency provision only. Looks good on the surface, but should be considered as a alternative of last resort, not first resort. Its very presence may encourage irresponsible underwriting in the transitional period. Its good that… Continue Reading ›