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Temporary High Risk Insurance Pool Program. Section 1101 of the Patient Protection and Affordable Care Act. Troy Oechsner Deputy Superintendent New York State Insurance Department United Hospital Fund Roundtable April 23, 2010. High Risk Pool Timetable.
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Temporary High Risk Insurance Pool Program Section 1101 of the Patient Protection and Affordable Care Act Troy Oechsner Deputy Superintendent New York State Insurance Department United Hospital Fund Roundtable April 23, 2010
High Risk Pool Timetable • Establishment. The Secretary of HHS must establish a high risk pool program within 90 days of enactment (June 21). • Letter of Intent. States must submit a letter of intent to the Secretary of HHS by April 30th to be eligible to receive federal funding.
High Risk Pool Timetable (continued) • RFP. HHS will set out a request for proposals detailing specific requirements for state high risk pools (about May 1). • State Proposal. In response to RFP, states will submit a specific proposal (flexible deadline, first come first serve, through summer).
HHS Guidance • Letter to states (April 2) • Call with NY Dept. of Insurance (April 13) • E-mails (ongoing) • Call with all states (April 22)
Other Outreach • NY State Agencies • Other States • Stakeholders
Implementation Considerations • The Secretary may contract with states or nonprofits. If a state is not going to establish a high risk pool, the Secretary must establish a high risk pool within the state. • States must maintain the current levels of funding (if any) for established high risk pools.
Considerations • Purpose • Insure the uninsured • Insure high risk people in need • Statewide or Regional • Risk: At Risk or Not
Considerations • Care Management Features • Provider network • Medical management • Benefit Package • One or more • Comprehensiveness/actuarial value • Reach the uninsured • Do no harm to existing markets
Considerations Pricing • Lower rates • Better risk pool/reach more people? • More funding per head/hit enrollment cap • Higher rates • Impact on risk pool • Affordability • Less funds per head/ensure availability of program
Considerations Eligibility: How Flexible on Criteria? • Pre-existing condition • Strict vs. expansive • Crowd out • Purpose • Exceptions? • Migration of DP risk? • Citizenship: What does “legally present” mean? • Standard • Proofs
Considerations • Funding Must strike balance • Helping the most people • Helping those most in need • Reallocation of Funds in Two Years Unspent funds at risk • Transition to Insurance Exchange
Some Basic Options(with many variations) • Existing DP:Apply funds to existing Direct Pay market • New HRP:Develop a new state-run risk pool for eligible New Yorkers • New DP Product. Apply funds to new direct- pay product for eligible individuals • FHP. Put funds into Family Health Plus Buy-In • Do Nothing. Let HHS establish