ACA Title 1, Sec. 1333. Provisions relating to the offering of plans in more than one state:”Good” – Mostly – Establishes multi-state health plan offerings. This section of the ACA provides for health plan providers to offer the same plans to the individual and/or small group markets in one or more states. Their state of domicile… Continue Reading ›

ACA Title I, Sec. 1332. Waiver for state innovation: “Good” – Supports innovation by states. Always a good provision, but it also comes with selected limitations including: must include 10 year budget neutrality for HHS, at least provides coverage compatible with “Essential Health Benefit Coverage”, and cost sharing levels no greater than the limits in the… Continue Reading ›

ACA Title I, Sec. 1322. Federal program to assist establishment and operation of nonprofit, member-run health insurance Issuers: “Ugly” – Unnecessary and misguided. This section sets up a whole federal system for the awarding of grants, loans and contracts to stimulate consumer run, non-profit health insurance plans with the “catchy” name of “Consumer Operated and Oriented… Continue Reading ›

ACA Title I, Sec. 1321. State flexibility in operation and enforcement of Exchanges and related requirements: “Good” – Provides option for state to operate insurance “exchange” including standards and protection from federal preemption. This section of the ACA provides for states to operate an insurance exchange and that the Secretary of HHS will promulgate standards and… Continue Reading ›

ACA Title 1, Sec. 1313. Financial integrity: “Good” – Basic requirements for financial record-keeping, audits, reports and oversight of exchanges. This section requires that exchanges keep sound financial records, conduct periodic audits, report to the federal government, be investigated by the GAO and be monitored for patterns of abuse or filing of false claims. This is… Continue Reading ›

ACA Title 1, Sec. 1312. Consumer choice. “Ugly” – In appropriately limits risk pool for individual and small group market. This section of the ACA inappropriately limits the use of one risk pool for all individual plan members and small employer group members. The way I read this it prohibits offering a “Wellness- oriented” risk pool… Continue Reading ›

ACA Title 1, Sec. 1311. Affordable choices of health benefit plans. “Good” – Established the ground rules for the development and operation of “exchanges.”This section of the Law covers the provision of grants to states for the development of “American Health Benefit Exchanges” including assistance to states to establish exchanges using grant funds, including the… Continue Reading ›

ACA Title 1, Sec. 1304. Related definitions. ‘Good” – Defines individual and group markets and large and small employers.This section simply defines the basic terms including “Individual Market” and “Group Market” and the terms “Large Employer” (101+ employees) and “Small Employer (≤100 employees) and transitional rules for their treatment as they grow or change. States… Continue Reading ›

ACA Title 1, Sec. 1303. Special rules: “Bad”- Identifies special ground rules for handling abortion services. This provision provides general protections for consumers to have access to health plans through exchanges that cover abortion services. It also protects state laws from preemption by federal laws and established ground rules for public funding of abortion services. It… Continue Reading ›

ACA Title 1, Sec. 1302. Essential health benefits requirements: “Bad”- Too comprehensive and wasteful. This provision establishes the set of benefits and maximum out-of-pocket (MOOP) cost sharing limits that will now apply across all qualifying insured plans. It includes a broad range of benefits by category and on the good side includes a new provision for… Continue Reading ›