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Questions and Answers for HCR Plan Finder Data Entry

Issuer Questions

Getting Started

Q: [Issuer] What do HIOS and CMP stand for?

A: HIOS is the Health Insurance Oversight System, and is the system used for collecting insurance company and product information.

CMP is the Content Management Portal which is the system used for collecting plan-level pricing and benefits information.


Q: [Issuer]
How do I get a product ID number?

A: Issuers obtain product ID numbers through HIOS. A memo was sent to all issuers on August 20, 2010, which provides further directions on how to obtain the pre-populated data collection spreadsheet. This spreadsheet provides your product data with the associated ID, which should be used in the CMP. The memo can be found at http://www.hhs.gov/cciio/gatheringinfo/index.html.


Q: [Issuer]
What is a SERFF number?

A: The NAIC maintains a reporting service called SERFF which is used by 27 states to track submissions from insurance carriers to state DOI commissioners. If you are not participating in the use of SERFF, you are not being required to obtain SERFF numbers. However, if you have a SERFF tracking number associated with a product or plan's approval with the state we are requiring that the tracking number be entered through the HIOS tool as well as the CMP for Plan Finder plans. The SERFF field is presented in the data collection tool as “optional” since many states do not use this system, but where a number exists, its reporting is required.

Our primary purpose in collecting the SERFF number is for reconciliation and tracking of information between the product and plan levels of data collection. As such, we ask that plans be marked with the SERFF number associated with the product-level filing.


Q: [Issuer]
What is the relationship between the HIOS data collection tool and the CMP data collection tool?

A: The HIOS system is the system of record for Issuers and their product level data to which an Issuer’s Plan Finder plans must be matched through the CMP. The CMP collects the portal plan benefits and pricing information, which gets displayed on the HealthCare.gov Plan Finder. Both systems will remain active, and products must be entered into the HIOS tool before the Finder plans associated with them can be properly enumerated when entering data into the CMP system.


Q: [Issuer]:
Which tool should I use to enter pricing/benefits information?

A: Please use the CMP tool for entering plan-level pricing/benefits information. If you have questions regarding the CMP, please email cmp-support@ehealth.com or call 1-877-425-3708.

Also, use HIOS to enter the Issuer identification and product level information. If you have questions regarding products/HIOS, please email their helpdesk at Insuranceoversight@hhs.gov or call 1-877-343-6507.


Q: [Issuer]
Can we get an extension to file?

A: Data that is reported to the HIOS System or the Content Management Portal (CMP) should be submitted within the suggested time frames based upon the submission windows listed in official memos sent from OCIIO through HIOS. If your information cannot be entered during that time for any reason, there will be additional refreshes on a regular basis. Denial, application and up-rating information is refreshed on a quarterly basis based on the following schedule:

March refresh – Third quarter of calendar year 2010 (July 1 to September 30, 2010)

Data regarding applications initiated in one reference quarter but acted upon in a subsequent reference quarter should be reported for the quarter in which the action is taken.


Q: [Issuer]
When should I enter my data into HIOS or CMP?

A: All products, whether they are opened or closed for enrollment, should be entered into HIOS. Products not yet approved by your State DOI may be entered into HIOS but must be marked “closed” until it is approved. In the CMP, only plans that are for sale to the general public and approved by your State DOI should be entered.  


Q: [Issuer] Should I use the company’s legal or marketing name when entering information into HIOS and CMP?

A: Issuers should enter the company’s legal name into HIOS and the company’s marketing/brand-name into CMP.

 

Brochures and URLs

Q: [Issuer] Do issuer web sites and brochures have to be 508 compliant?

A: While it is strongly encouraged that issuers make their data accessible to all users, Section 508 does not apply to private firms which do not receive federal funding. Any materials posted on the Plan Finder that can be directly accessed by the public will need to be 508 compliant. Links to items hosted by your own website do not have the same restrictions.


Q: [Issuer]
What is meant by a summary of benefits/brochure?

A: A summary of benefits refers to a short statement outlining for consumers the benefits available to those who enroll in a given product. Many states require that these be filed for products offered within their borders, and most issuers create these for marketing purposes as well. These summaries are often referred to as brochures. The Summary of Benefit brochures that are displayed on the Plan Finder are pulled from information you enter into HIOS.


Q: [Issuer]
Are we required to report formulary and provider network URLs into HIOS?

A: If the health insurance product utilizes a provider network and/or formulary list as a component to set the base price structure, then your organization is required to report these URLs in HIOS so consumers may access this information.

 

Applications, Denials, and Uprating

 

Q: [Issuer] What is the operational meaning of applications, denials, and up-rated offers?

A: “Number of applications received” refers to the total number of applications which were processed for enrollment under the product during the reference quarter according to the schedule specified. For Plan Finder purposes, an application is a request for insurance coverage, not a method for making administrative changes (Example: a change of member’s home address.)

If an existing customer voluntarily changes plans or benefits coverage within your company, and is required to re-submit an application in order to re-enter the application or underwriting process, then that should be reported as an application.

“Number applications denied” refers to the total count of attempts by applicants to enroll in the product; Issuers are required to report the number of applications which were denied for enrollment, or pended for healthcare intervention (for example until after surgery), or not accepted for the terms of an application but rather offered a counteroffer (for example offered a policy under a higher deductible, or with a rider that limits coverage for a condition or body part) during the reference quarter.

“Number up-rated offers” acknowledges that actual premiums may vary widely for most products. Issuers are required to report the total number of offers issued for a product which were “up-rated,” such that the under-writing process resulted in a premium quote higher than the base rate, which represents the lowest rate available to all consumers for that product, for the reference quarter. Non-health specific factors used by the Plan Finder to modify base rates (such as smoking and age,) which may result in a higher premium are not considered determining factors when reporting the number of up-rated offers.

Reference Quarters for Reporting on Applications:

March refresh – Third quarter of calendar year 2010 (July 1 to September 30, 2010)

Data regarding applications initiated in one reference quarter but acted upon in a subsequent reference quarter should be reported for the quarter in which the action is taken.


Q: [Issuer]
There are three types of data requested: Number of applications, number of denials, and number of up-ratings. Is this information required at the product or plan level?

A: We are requiring this information only at the product level. This information must be reported through the HIOS tool and updated per the OCIIO published schedule.

Q: [Issuer] How do I count applications, denials, and up-rated offers for family insurance policies?

A: When reporting applications and denials, we are referring to the application level. For example, if someone requests a policy to cover their family, that is one application.

Denials and up-rated offers are also at the application level, but any denial or up-rating means that that this applies for the entire application. Thus if someone requests family coverage for a family of five and two children are denied coverage, that is one application, and one denial. If the policy is offered with a premium surcharge applied to two children due to pre-existing conditions, then that would be one application and one rate-up.

If you close a plan after the reporting quarter, you are still required to report the actual number of applications, denials and up-rates for the product for the reporting quarter (or partial quarter) in which the product was still open.


Q: [Issuer]
What are the reporting periods for the three product level application elements concerning denials and policies up-rated?

A: For each of the following: number of applications, application denials (including pended and alternate offers), and up-rated offers, the Issuer should report a total sum for a given quarter. Quarters are reported based on a staggered schedule:

March refresh – Third quarter of calendar year 2010 (July 1 to September 30, 2010)

Data regarding applications initiated in one reference quarter but acted upon in a subsequent reference quarter should be reported for the quarter in which the action is taken.


Q: [Issuer]
When we send in our small group data for the number of applications, are we required to submit them from a group or member level?

A: When reporting the number of applications for the small group products, you should submit them at the group level.

Pricing Information

 

Q: [Issuer] How are “premium rates” construed for this data collection?

A: Premium rates for HIOS are being represented as estimates and a starting point from which the actual premiums will change due to underwriting based on health status and pre-existing conditions.  As such, we ask for the “base” rate which constitutes the lowest rate for a person who does not incur additional charges as a result of medical under-writing, and is identifiable by the simple demographic categories for which we collect consumer information. We welcome Issuers to also participate in identifying additional factors and methods that they use in the calculation of base rates so that we may continuously refine the rate estimation engine.

Q: [Issuer] My company sells plans with tiered deductibles, meaning there is more than one deductible amount available. When entering plan-level benefits into CMP, how should I input the various deductible amounts?

A: While companies may define a single “plan” as having multiple payment levels and benefits, a “portal plan” for display on the Plan Finder refers to a unique combination of benefits and pricing. As such, if there are multiple deductibles combined with different benefits or base premiums, these constitute multiple portal plans for reporting purposes. If one particular combination accounts for at least 1% or more of the Issuer’s enrollment in that market, that combination must be reported as a distinct portal plan. If these combinations are marketed under a common name, a suffix denoting the deductible should be used for differentiating between them.

Please note this guidance does not pertain to portal plans that utilize tiered provider networks.

Q: [Issuer] Should out-of-pocket limits be included in the deductible?

A: Issuers should always include the deductible in the out-of-pocket limit entry. Despite the fact that the CMP tool currently allows Issuers to mark whether the out-of-pocket limit includes or excludes the deductible, our guidance is that you must include the deductible in the out-of-pocket limit entry. The CMP tool will be updated to reflect this requirement, in the near future.

Q: [Issuer] How do I report plans with no out-of-pocket limits?

A: If a plan has an unlimited out-of-of-pocket limit, please enter “999999999” (no quotation marks) in the “Individual Out-of-Pocket Limit” and/or “Family Out-of-Pocket Limit” fields in CMP.

If your previously-submitted plan has an unlimited out-of-pocket limit and you’ve incorrectly entered “0”, you must correct the data. Failure to enter data correctly may result in inaccurate display and or possible suppression of those plans.

Q: [Issuer] How do I report plans with no out-of-pocket limits for family-only plans?

A: For the individual out-of-pocket and deductible fields, enter the values for the first person on the plan if the plan has separate deductibles/out-of-pocket limits. If the plan has an aggregate deductible or out-of-pocket limit, enter the relevant family value in the individual field.

 

Plans, Products, and Enrollment

 

Q: [Issuer] What constitutes a “Finder plan”?

A: The Affordable Care Act and the Public Health Service Act do not define the term "Finder plan."  We have created this term to describe the entity which must be reported for consumers to compare their coverage options.  We understand that consumers apply for coverage under individual health insurance products that issuers develop and market to offer a package of benefits.  In applying for a package of benefits, we further understand that consumers are offered a range of cost-sharing arrangements, including deductibles and copayments but not including premium rates or premium rate quotes.  As a result, each package of benefits can be paired with a multitude of cost sharing options.  A “Finder plan” refers to the discrete pairing of a package of benefits with a particular cost-sharing option for which a manual/base premium can be calculated. 


Q: [Issuer]
How is product enrollment defined?

A: Enrollment is defined as “number of people covered to obtain total membership.” For example, if a product is sold to 1 person, but the policy covers that person and their spouse, enrollment equals 2, not 1.


Q: [Issuer]:
  How do we report enrollment numbers in HIOS and CMP?

A: For products reported in HIOS, Issuers are required to report enrollment for individual and small group products at the situs level. If you do not collect at situs level, you may report enrollment by membership residence.

For plans reported in CMP, enrollment numbers represent the total number of covered lives in that plan.

Enrollment numbers for both HIOS and CMP should be reported as of the last date of the previous quarter:

March Plan Finder refresh – Update enrollment numbers as of December 31, 2010


Q: [Issuer]:
  How does the one percent standard work? What Finder plans must be submitted?

A:While issuers may submit all eligible Finder plans, for each zip code, issuers are required to submit information on at least all plans that are open for enrollment and that represent 1 percent or more of the issuer’s total enrollment for the respective individual or small group market within that zip code. While we do not require reporting of enrollment numbers at the zip code level, this is the requirement for determining whether a Finder plan must be submitted.


Q: [Issuer]
It seems as if every combination of benefits constitutes a different Finder plan. Is there a way to combine benefit levels to show all offerings in one plan?

A: Finder plans represent one unique combination of benefits and cost sharing arrangements, therefore all price structures, such as tiered deductibles, must be represented as separate plans on the Plan Finder. While you are required to list those combinations which constitute 1% or more of enrollment in each of the individual and small group markets for a zip code, you are not limited to only report on those plans.


Q: [Issuer]
We do not actively market individual plans, but we are required to have a 30-day enrollment each year to let anyone into our individual plan. How do we list this type of plan? Do we mark it as “closed” most of the year and then “open” during open enrollment period?

A: Please mark it as “closed” when it is not open for enrollment and “open” when it is open for new enrollment.


Q: [Issuer]
How should we handle small business plans?

A: At this time, issuers are not required to submit to the CMP Finder plan level pricing or benefit information for the small group market.

The Plan Finder will continue to display small group information at the product level. Issuers should continue to update small business information at the product level through HIOS, and ensure that information is accurate and up-to-date.

Further guidance will be provided to issuers on data requirements for the collection and display of small group Finder plans.


Q: [Issuer]
My company offers the in-network piece of a POS product, but the out-of-network is filed under a separate NAIC code. Should both companies enter these products?

A: We are interested in trying to show consumers their meaningful choices, and thus do not want to represent these as different products. For products which are exclusively parts of POS combined services, we ask that the product type be identified as POS, but that you enter either “in-network” or “out-of-network” in the “Type – Other” field.


Q: [Issuer]
If a product is open for enrollment but enrollment is very small, can we check "Yes" to opt-out of Phase 2?

A: No. As the documentation notes, this field is intended to differentiate between products closed for enrollment and products with open enrollment. Plans which represent less than 1% of enrollment in a zip code for the individual market do not have to be reported, even if it is part of a product marked “open” in HIOS.


Q: [Issuer]
We have a product line which we are authorized to sell but has never been offered and does not have any enrollment. Do we need to report on this product?

A: You have the discretion to report or not on plans with enrollment below 1% of a zip code in the data requirement.


Q: [Issuer] We are concerned about plans which will only be authorized for sale in a part of a zip code. How do we report on partial zip codes?

A: For products submitted into HIOS, enter the zip code in which a partial zip is covered. For plans submitted into CMP, please utilize the 1 percent test to determine the zip codes to enter. Only plans with active enrollment representing 1 percent or more of the issuer’s enrollment in that market are required to be reported.  

 

Riders

 

Q: [Issuer] Can we report optional riders, such as pharmacy benefits, so that they will be displayed on the Plan Finder? How should we report this?

A: Optional or mandatory riders which would be reflected in premium rate changes and fall into the following benefit categories should be reported for Finder plans: pharmacy, maternity, mental health and substance abuse services.  

Only the specific combinations of benefits and cost sharing which include these benefits AND meet the 1 percent enrollment test are required to be reported.  In meeting the 1 percent enrollment requirement, we advise that issuers focus their attention on combinations of benefits and cost sharing that have proven popular with consumers, rather than trying to submit all the possible combinations.  We may establish priority rules for processing and displaying Finder plans from issuers that submit large numbers of Finder plans beyond what a 1 percent test would suggest be reported.


Q: [Issuer]
How should we represent the previously noted optional or mandatory riders in our plan listing through the CMP tool?

A: Combinations which include the riders specified above should be entered as separate Finder plans, with the benefits specified in the appropriate section of the benefits template. Rate tables for this plan should reflect the inclusion of the rider cost. When entering the optional benefit, it must be followed by an '*' in those fields.  On the Plan Finder, we will clarify that benefits delineated with an '*' are optional.

In reporting names of plans, we suggest that Issuers include a modifier that delineates optional riders that have been included in order to avoid confusion when consumers review and reference coverage options (e.g., “PPO 500 with Maternity”).


Q: [Issuer]
Affordable Care Act regulations required certain services be covered. Many insurers provided this increased coverage through riders. Can these benefits still be displayed? 

A: These benefits, even if represented as riders, should be included in the benefit and rate submissions, assuming that requirements of the State for adding these benefits to their policies have been met. Because these benefits are not optional, they should not be marked with an “*” However, the cost of these services need to be reflected in the rates.

 

Attestation

 

Q: [Issuer] To what does the CEO or CFO have to attest in CMP?

A: We are requiring as a condition for plans to display that the CEO or CFO attest to the accuracy of the data as stated below.  Also concerning display of plans, at this time, we are making it optional that the CEO or CFO attest to the completeness of the data as stated below. In the near future, we intend to include the attestation to completeness of the data as a condition for display.

Accuracy provision of the attestation:  I attest in my capacity as CEO or CFO that I have examined the plan benefit and pricing data submission that was submitted through the Department of Health and Human Services (HHS) Content Management Portal (CMP), and that to the best of my information, knowledge, and belief it accurately represents the required plan benefit and estimated pricing data based on current template parameters.

Completeness provision of the attestation:  I further attest that our submissions as a whole to the CMP represent plan benefit and pricing information for all plans that are offered by this organization that are open for enrollment and that represent one percent or more of the organization's total enrollment for the relevant market within any given zip code.


Q: [Issuer]
Will our CEO or CFO have to attest every time we provide updates to the Plan Finder?

A: CEO or CFO attestation should occur on updates made to CMP. Since users may update benefit and pricing information more frequently than annually, we are requiring updated data submissions whenever an Issuer changes the premiums, cost-sharing, types of services covered, coverage limitations, or exclusions for one or more of their individual or small group Finder plans. Our regular updates will also reflect these changes.

 

State Questions

 

Q: [State] What were the data requirements for states for the Plan Finder’s launch in July 2010?

A: States Departments of Insurance were asked to provide 3 types of data through our online tool, Heath Insurance Oversight System (HIOS). This included:

  1. All licensed Issuers for whom the Issuer has filed forms, or is otherwise known to sell major medical insurance in the individual and small group markets. Note: the Plan Finder is not gathering information on the large group market at this time.
  2. Counts of products to use as a validation check against what we receive from Issuers.
  3. One general contact for each insurance company, which we can use to reach out to Issuers that may have been missed through other channels.

Data submitted by states is not currently displayed on the Plan Finder. However, the information was used to determine the universe of all possible Issuers, ensure we gathered information from all Issuers in these markets, and determine appropriate means of presenting the data online.

Our intent was to obtain the most accurate portrait of the current market. We understand that many active insurance products may have been filed years ago, and different states have different regulations on certification. We asked states do the most thorough job given the time allotted.

States are not currently required to update their data submissions. Should there be new data reporting requirements for states, DHHS will provide additional guidance and training.

Some states also provided a listing of all insurance companies who are authorized to sell health insurance in their states, as requested by OCIIO.


Q: [States]
How will DHHS ensure that the Plan Finder is consistent with the information provided on states' websites?

A: The Plan Finder links directly to state Medicaid, CHIP and high risk pool web pages. HealthCare.gov also links to InsureKidsNow.gov for CHIP information. In addition, CMS / CMSO works with states to review the information that CMS / CMSO is pulling from federal records about Medicaid and CHIP.

We are working with NASCHIP to collect and verify information in cooperation with affected states on the high risk pools. Information on major medical products and plans sold in the individual and small group markets is verified by Issuers who provide the information, and this information is also made available to states if they decide to verify what Issuers report to us. We welcome feedback from states on these fronts.

 

Q: [States] Will grants be made available for states to monitor and suggest corrections to the Plan Finder?

A: At this time no specific grants have been identified for this purpose.

 

Q: [States] How will states be consulted to help improve the Plan Finder?

A: States are encouraged to provide feedback on the Plan Finder regulation and website by emailing OCIIOPlanFinder@hhs.gov . In addition, the new Office for Consumer Information and Insurance Oversight is the primary driver in establishing working relationships with the states to improve the Finder and make sure that the interests of consumers, issuers, and the state are understood and considered.

 

Questions from Issuers and States

Training and Help

 

Q: [Issuer / States] Who can I contact if I have a question not answered in the Q&A?

A: To obtain answers about questions related to the HIOS System, contact the HIOS Help Desk at either 1-877-343-6507 or insuranceoversight@hhs.gov. If you have questions about the Content Management Portal (CMP), contact the CMP Help Desk at 1-877-425-3708 or cmp-support@ehealth.com.

 

Q: [Issuer / States] Will we be able to access the training PowerPoint presentations from the website?

A: Yes. The slides and webinars can be accessed at http://www.hhs.gov/cciio/gatheringinfo/.


Q: [Issuer / States]
Where can I get answers to my non-Plan Finder health care reform questions?

A: The government has set up a central email address to submit health care reform questions at: healthreform@hhs.gov. For other questions or to reach out to a particular HHS office or agency, please refer to the HHS contact directory at: http://www.hhs.gov/ContactUs.html


Q: [Issuer / States]
We know the government is emphasizing transparency. Will the information going into the Plan Finder data collection be made available electronically for public use? If we have concerns about the uses to which the data we submit may be put, how do we communicate those to the government?

A: All of the data items requested are being used either to present to consumers, to validate other data elements, to assess the effectiveness of the Plan Finder, or to develop strategies on how best to present information. In addition, as stated in the background section of the Plan Finder regulation, we plan to provide information, consistent with applicable laws, in a format that is accessible for use by the public. We obtained comment on the Plan Finder regulation and are currently considering how best to approach public use of the data collected for the Plan Finder.

 

Getting Started

 

Q: [Issuer / States] What insurance products are covered by the data requirement? What is meant by “major medical”?

A: The data requirement is for “major medical” policies and plans. Until we develop a standard definition in regulation for “major medical” we have provided a general meaning to include coverage for basic health services, excluding short term policies. Basic health services include such things as: physician services, inpatient and outpatient hospital services, medically necessary emergency health services, medical treatment and referral services, diagnostic laboratory and diagnostic and therapeutic radiological services, home health services, and preventive health services. The data requirement does not cover supplemental health service products.

 

Q: [Issuer / States] Our state operates with a small group definition which differs from that proposed by the Affordable Care Act. How do we report the data?

A: Reporting to the Plan Finder should be based on the state law and definitions applicable at that time.

 

Q: [Issuer / States] What is the difference between a product and a plan?

A: A health insurance product is defined as a package of benefits an issuer offers that is reported to State regulators in an insurance filing or the sets of benefits which are associated with various versions of cost sharing, i.e. deductibles, co-payments etc. These are collected in HIOS. Plans are a specific combination of benefits, cost sharing and premium which are offered to consumers, and are collected in CMP.

 

Template Information

Q: [Issuer / States] How do I obtain a copy of the HIOS template and/or instructions for use?

A: The template is available at http://www.hhs.gov/ociio/gatheringinfo/. It can also be accessed by contacting the help desk by phone or email.


Q: [Issuer / States]
How do I access the CMP templates?

A: To access the CMP template, you must log into CMP. 

 

Q: [Issuer / States] Will we continue to use the excel template to report information?

A: We will continue to use the excel template for large data submissions outside of the Content Management Portal. States and issuers will be given direct access to their data via the internet for future validation and changes. For the Content Management Portal we are looking at options for issuers to have the availability to go into the portal and change information directly.  Until such a process is communicated by HHS, issuers should continue to work with the CMP Help Desk for assistance in making any changes to their plan level information.


Q: [Issuer / States]
Will we be able to use the template with older versions of excel or other spreadsheet programs such as Open Office?

A: No. Excel 2003 or greater will need to be used. If you are having a technical problem please contact the help desk.

 

Data Discrepancies and Correction

 

Q: [Issuer / States] Can you provide additional information on how data discrepancies will be verified or corrected?

A: Issuers should review their data in the Heath Insurance Oversight System (HIOS). If an issuer has identified a data discrepancy between their submitted file and the data displayed in the system, they should contact the HIOS Help Desk. The Help Desk will create a ticket and investigate the root cause of the discrepancy. If the issue is caused by the data submission, the Help Desk will request that the issuer correct their file and resubmit. If the issue is caused by the system, we will be responsible for correcting the issue.

 

Q: [Issuer / States] Can errors in HIOS be corrected without having to resubmit the entire data file?

A:  It depends on the nature of the issue. If the error has occurred because of a problem in the issuer's data file, then the entire data file must be resubmitted. If the error has occurred because of a defect in our system, we will correct the issue without requiring a revised file submission. Users should contact the HIOS Help Desk at either 1-877-343-6507 or insuranceoversight@hhs.gov if they have questions about a particular error.


Q:
[Issuer / States] Can errors in CMP be corrected without having to resubmit the entire data file?

A:  It depends on the nature of the issue. If the error has occurred because of a problem in the issuer's data file, then the entire data file must be resubmitted. If the error has occurred because of a defect in our system, we will correct the issue without requiring a revised file submission. Users should contact the CMP Help Desk at 1-877-425-3708 or cmp-support@ehealth.com if they have questions about a particular error.

 

Plans with Limited or Private Enrollment

 

Q: [Issuer / States] Do I need to enter self-funded Multiple Employer Welfare Arrangements?

A: Where MEWAs are regulated by state insurance departments and they offer individual and small group products, we require that a row be entered for the product in HIOS. Identify the type by the drop down box as HMO, PPO, etc. as it applies. In the Type-Other field, enter a value of “Association.” Currently, we are not displaying these products, therefore enter “yes” in the opt-out field.

 

Q: [Issuer] I have a product which is only offered to members of a specific association (like the Lion’s Club or AARP) in my state. How do I enter these?

A: Enter a row for the product, identify the type by the drop down box as HMO, PPO, etc. as it applies. In the Type-Other field, enter a value of “Association.” Currently, we are not displaying these products, therefore enter “yes” in the opt-out field.


Q: [Issuer]
We have products which are only available to limited populations such as professional associations, cooperatives, etc. Do those need to be reported?

A: Yes. All major medical products approved for sale in the individual and small group markets are to be reported in HIOS. If a product has plans offered to both the general public and to associations, please treat it as you would any other general issuance product. If all the plans under this product are sold only to associations, cooperatives, etc, then you can indicate this by entering “association” in the “Other Product Type Description” field.


Q: [Issuer]
Can an issuer report on association based insurance Finder plans if they would like to?

A: At this time, you should report association products in HIOS, but not report association Finder plans in CMP. We are working on methods to incorporate association products into the Plan Finder.

 

Q: [Issuer / States] Do we need to report on Medicare supplements, Medigap policies, accident insurance, single condition coverage, short term or other limited benefit insurance?

A: No. Plan Finder data collections are aimed at gathering comprehensive major medical health insurance only.


Q: [Issuer / States]
We have a set of individual conversion policies which only go into effect if the large group policy of which they are a part closes. Do these need to be reported?

A: We assume that conversion policies are drafted from major medical products approved to be sold in the individual and small group markets and therefore this information at the product level will be captured. Only plans with active enrollment representing 1 percent or more of the issuer’s enrollment in that market are required to be reported. We assume that enrollees in conversion plans would only be counted toward enrollment in a plan after conversion has happened.


Q: [Issuer / States]
Why are closed blocks, which are not accepting new members, required to be reported?

A: Issuers are required to provide information on major medical products in HIOS for which they are licensed to sell in the individual and small group market. States are requested to provide counts of such products. There are three reasons we are asking for this data to be included. First, we want to make sure we have the complete universe so that we understand the market and whether we are adequately representing what is happening. Second, closed blocks may not be treated the same way in every state, and a block might be re-opened.

Third, since many people are enrolled in closed blocks, excluding them would not allow us to understand why an issuer who indicates they have enrollment at a given level has only reported plans for a significantly smaller number. The closed products will not be displayed online at this point, however we are still exploring whether people who have individual insurance currently in a closed block might want to compare their benefit structure to the benefit structures on other products, whether we should use a threshold of enrollment under which we would not show the closed products and whether showing any closed products could cause confusion for people who do not have access to such products. If we would show any closed products, we would indicate on the Plan Finder that they are closed to enrollment. Issuers are not required to report Finder plans that are closed to enrollment into CMP.

 

URLs

 

Q: [Issuer / States] What happens when my Brochure, Formulary or Provider Network links fail? What can I do to have my organization’s links displayed on the Plan Finder and when may I update the URLs?

A: The DHHS/OCIIO will only display URL links that directly provide consumers with the requested information. Reviewers examine each URL submitted in your templates to ensure the links provided are valid, appropriate, not broken, and provide sufficient information for the consumers. The landing page of the URL must directly contain the information required (for example, a benefits brochure, formulary, or provider network) or have a very visible, easy to understand, second link to the specific information. A third link (or click) is only allowed if the previous link required consumer input to assist in targeting the information available, and if the third link lands on the specific information being sought. In addition, only links that provide comprehensive information on the subject are approved.

The brochure link must take users to detailed benefits and cost sharing information, similar to summaries of benefits filed with State Departments of Insurance. A link to a web page that has a statement about the availability of comprehensive benefits and a list of special programs or services will not be considered sufficient information for the purposes of the reporting requirement.

In brochures for small group, the following items must be present in order to pass OCIIO validation: out of pocket maximum, annual deductible, emergency care, hospitalization, and primary physician office visit.

In brochures for individual/families, the following items must be present in order to pass OCIIO validation: out of pocket maximum, annual deductible, emergency care, hospitalization, primary physician office visit, specialist office visit, and lab/x-ray/radiology services.

If the plan does not cover a benefit(s) listed above, the brochure must provide a clear statement to this effect for the benefits not included in the plan. Failure to comply will result in, at minimum, suppression of the link on the Plan Finder and a published note stating that insufficient link information was provided.

Formulary links must contain all covered drugs, not just preferred drugs. A fully comprehensive formulary brochure is one that contains a list of all approved medications indicating their position within the pricing structure.

If the formulary list is extensive, and there are a limited number of excluded drugs, the formulary listing may provide a complete categorization of all covered drugs and specifically list all excluded drugs within the formulary. Failure to comply will result in, at minimum, suppression of the link on the Plan Finder and a published note stating that insufficient link information was provided.

For provider network links, issuers must submit a direct link to a comprehensive list of in-network providers or a searchable provider directory. Consumers must be able to access this information within a total of three mouse clicks, inclusive of the first mouse click on the HealthCare.gov web page. If you have an Indemnity product and do not have a link to a Provider Network, please enter the word “Indemnity” (no quotation marks) in the “Website address (Provider Network)” field in HIOS. Failure to comply will result in, at minimum, suppression of the link on the Plan Finder and a published note stating that insufficient link information was provided.

Your organization will be allowed to resubmit data every month during the regular refresh. Notices of when these regular refreshes will occur will be released in memos to your organization’s contacts through the HIOS system. If your organization successfully resubmits data to us during the submission window, and we find that the URLs are satisfactory, then the resubmitted data will be displayed once it is confirmed by OCIIO.

 

Q: [Issuer] If my URL fails to meet OCIIO’s requirements in the HIOS system, is there any way that we can apply for an exception on that link?

A: No, all issuers must meet the requirements outlined by OCIIO. If your organization fails to provide an acceptable link, then the website will display either that a link was not provided, or that a correct link was not provided. Your organization will be allowed to resubmit data every month during the regular refresh. Notices of when these regular refreshes will occur will be released in memos to your organization’s contacts through the HIOS system. If your organization successfully resubmits data to us during the submission window, and we find that the URLs are satisfactory, then the resubmitted data will be displayed once it is confirmed by OCIIO.