… to solve the problems created by the Obama administration and Obamacare. Back on Dec. 6 I wrote about the provision in Obamacare that might leave doctors and health care providers in a position where they are told a patient has coverage, but they end up not getting paid. Now, but Obama administration is pressuring insurance companies to pay for procedures and care even if no premiums have been paid.
As usual, the document is hard to read, but I’ve tried to pluck out the most important parts. Because of the “delays,” the Department of Health and Human Services wants coverage for those who select plans after Dec. 23 and before Jan. 31, 2014 to be retroactive to Jan. 1, 2014 even if no premiums have been paid.
SUMMARY: This interim final rule amends the date by which a qualified individual must select a qualified health plan (QHP) through any Exchange for an effective coverage date of January 1, 2014. This rule generally allows consumers to select a QHP until December 23, 2013, which is a change from the previously stated regulatory date of December 15, 2013, but permits State Exchanges to select a different date. It also establishes a related policy regarding the date by which a consumer needs to pay any applicable initial premium to ensure timely effectuation of coverage. This rule pertains to the individual market and Small Business Health Options Program in both the Federally-facilitated Exchanges and State Exchanges. This rule does not change the plan selection or premium payment dates for coverage offered outside of the Exchanges.
Since the publication of the Exchange Establishment Rule and the Draft Enrollment Guidance, there have been unforeseen barriers to enrollment in the Exchanges.
In §155.410(c)(1)(v), this rule states that the Exchange may allow issuers to provide for a coverage effective date of January 1, 2014 for plan selections received after December 23,2013 but on or before January 31, 2014, if a QHP issuer is willing to accept such enrollments. We note that if the QHP issuer allows enrollment in January for a January 1 coverage effective date, any services provided to the enrollee in January would need to be covered retroactively as if the enrollee had been enrolled from January 1. QHP issuers in an FFE will have this option, and while we understand that late enrollment may create challenges for issuers in processing the premium payments and providing retroactive coverage, we urge issuers to consider a January 1, 2014 coverage effective date for plan selections after December 23, 2013 for this year, given the newness of the enrollment process.
Remember, there is also a 90-day grace period before insurers can drop patients who fall behind on premiums. Then there are out-of-network issues. In general, policy dates are not in-line with the dates agreements are made between physicians and other health care providers. A network agreement between a hospital and an insurance company can end at any time. During the negotiations, and insurance company would send a letter to members letting them know there might be a future issue, but the plug can be pulled at any time. The HHS is strongly suggesting the insurance companies cover care by out-of-network providers if the provider was listed as in-network at the time of enrollment. This is not how it’s usually done.
For those directories that cannot be maintained in a current status, we believe that it would be reasonable for issuers to consider services received out-of-network as having been received in-network (subject to in-network coverage and cost-sharing standards) with respect to any provider listed in the version of the provider directory as of the date of that enrollee’s enrollment for the beginning months of coverage. We strongly encourage issuers to adopt this approach.
Huh. “Strongly encourage…” We all know what that means when it comes to this administration.