Following is a quick summary of recent developments regarding insurance exchanges received from our HUB Chief Compliance Officers:
The federal government will be operating insurance exchanges in more states than not. Now, two more states -- Idaho and New Mexico -- have indicated their platforms will not be operational on October 1, 2013. The federal government announced that it will step in and operate the technology necessary to run the two exchanges...but will consider these to be state-run exchanges.
Since the law passed in 2010, pundits have expressed concern that few health insurance carriers would participate in exchanges and choices would be limited. Now, we appear to have the opposite challenge in states such as Colorado where 11 carriers announced plans to offer about 250 policies.
The federal government has released the Health Insurance Marketplace application form on the CMS website. Individuals will need to complete the form in order to secure coverage and request federal tax credits to subsidize the purchase of coverage. This application includes a page entitled Employer Coverage Tool, located within Appendix A of the application form that can only be completed by the employer. There is no indication at this point that an employer is required to complete this information. However, in the interest of maintaining goodwill with employees, an employer may want to create a completed or partially completed form, if multiple employee requests are expected.
We also have received the Exchange Notice employers must send to their workers before October 1. That Exchange Notice contains optional items (13 through 16) which most employers will not complete as the items are time-consuming and employee-specific. The federal agency assures HUB these items are purely optional, and failure to complete does not result in a fine or other negative repercussions. Please note that the optional items in the Exchange Notice are similar to the content requested in the Employer Coverage Tool.
HUB will keep you informed on new developments.