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Qualified Health Plans

 

Qualified Health Plan (QHP) Requirements

  • A QHP must be certified by each Exchange in which it operates.
  • A QHP must provide the essential benefits package, including providing essential benefits and meeting cost-sharing and actuarial value requirements.
  • A QHP must be offered by a health insurer that:
    • Is licensed and in good standing.
    • Agrees to offer at least one QHP in the Silver level and at least one plan in the Gold level in each Exchange in which it operates.
    • Agrees to charge the same premium for the same plan whether offered in or out of an Exchange.
  • Complies with regulations HHS establishes under PPACA § 1311(d) and any other requirements an Exchange may establish.

Benefit Design Essential Benefits Package

  • Essential Benefits Package. Services must include:
    • Ambulatory patient services;
    • Emergency services;
    • Hospitalization;
    • Maternity and newborn care;
    • Mental health and substance abuse disorder services “including behavioral health treatments”;
    • Prescription drugs;
    • Rehabilitative and habilitative services and devices;
    • Laboratory services;
    • Preventive and wellness services and chronic disease management; and
    • Pediatric services, including oral and vision care.
  • Must meet emergency coverage requirements (e.g., does not require prior authorization and charges the same cost-sharing for out-of-network emergency services as in-network).
  • Scope Equal to “Typical Employer Plan.” The scope of these essential benefits will be equal to the scope of benefits provided under a “typical employer plan” – according to HHS. To inform the decision, DOL will conduct a survey of employer plans, including multiemployer plans. Certification will be conducted by the CMS Actuary.
  • Definition of Benefits. In defining the essential benefits, requires HHS to:
    • Make sure all benefits are given equal importance and emphasis.
    • Not make coverage decisions, rate determinations or incentive programs or structure benefits that discriminate against anyone based on age, disability or expected lifespan.
    • Take into account the diverse health care needs of the population.
    • Make sure that essential benefits are not involuntarily denied to anyone on the basis of age or expected lifespan or disability, medical dependency or quality of life.
    • Periodically review and update essential health benefits.
  • Cost-Sharing
    • Limits cost-sharing (deductible, coinsurance, copayments, etc.) to Health Savings Account (HSA) cost-sharing limits in 2014 and then indexed annually to per capita premium increases measured after 2013.
    • Small group employer plans. Limits deductibles to $2,000/single, $4000/family.
    • Indexing
      • These limits can be raised by the maximum amount of reimbursement which is reasonably available to a participant under a flexible spending arrangement (FSA).
      • Indexes the individual limits annually to per capita premium increases measured after 2013. For any other plans, the limits will be indexed to double the individual increase. (PPACA § 1302)

 Levels of Coverage

  • Qualified Health Plans (QHP) must meet one of the 4 specified actuarial value tiers (determined by standard population, not plan’s actual population):
    • Bronze. Coverage of 60% actuarial value
    • Silver. Coverage of 70% actuarial value
    • Gold. Coverage of 80% actuarial value
    • Platinum. Coverage of 90% actuarial value
  • Requires Exchange-participating plans to offer at least one QHP in the Silver level and at least one plan in the Gold level.
  • Employer HSA contributions may be taken into account when determining actuarial value.
  • Catastrophic Plans. QHP may also be a catastrophic plan under certain circumstances.
    • Eligibility. Makes this plan available only in the individual market to individuals under age 30 and individuals who have received certification that they are exempt from the coverage mandate by reason of affordability or hardship.
    • Benefit Design
      • Covers 3 primary care visits regardless of deductible.
      • Covers essential health benefits after deductible is met.
      • Sets deductible at HDHP limit indexed to per capita premium increases after 2013.
  • Requires all QHPs to offer the same plans to children only (under 21). (PPACA § 1302(d))

 

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