CMS/CCIO Slides on Reporting Requirements

Health Insurance Issuer
Rate Review Training
Module 1: Rate Review Reporting
Requirements and Web-Based Data
Submission Training

Module 1: Rate Review Reporting Requirements and
Web-Based Data Submission Training

Information About the Issuer Training




Issuer training includes three modules:


Module 1: Rate Review Reporting Requirements and Web-based Data
Submission Training



Module 2: Technical Instructions for Completing the Preliminary Justification



Module 3: Technical Instructions for Calculating the Subject to Review Threshold

Additional training materials are available on
the CCIIO website: http://cciio.cms.gov/

Rate Review Program
Established by Section 2794 of the Public
Health Service Act (as amended by the Patient
Protection and Affordable Care Act)
 Rate Increase Disclosure and Review Regulation
(45 CFR §§ 154.101-154.301)


 Published

on May 23, 2011
 Effective on September 1, 2011

Overview of the Rate Review Program


Issuers report on rate increases at or above
“Subject to Review” threshold



Issuers submit a Preliminary Justification



Rate Review conducted by States or CMS



Preliminary Justification and review
determinations posted on healthcare.gov

The Applicability
Requirements apply to issuers in the individual
and small group markets
 Does not apply to


 Grandfathered

health plan coverage as defined in 45
C.F.R. § 147.140
 Excepted benefits as described in section 2791(c) of the
PHS Act

The Preliminary Justification


Consists of three parts:
 Part

I, the Rate Increase Summary Form

 Standardized,

 Part

II, Written Explanation of the Rate Increase

 Brief,

 Part

summary level rate data

non-technical explanation of the rate increase

III, Rate Filing Documentation

 Detailed

rate information, required only if CMS is
reviewing the rate increase

Timing of Preliminary Justification Submissions






Requirement Starts on September 1, 2011
States with Rate Filing Requirements: on the same
date filing is submitted to the State
States without Rate Filing Requirements: Prior to
implementing rate increases that go into effect on
or after September 1, 2011

HIOS Rate Review Module
 All

Rate Review issuer reporting requirements must
be submitted in HIOS

 Training

announcement included HIOS registration
information

 Issuers

should review the technical HIOS instructions
manual

HIOS Sign-In

HIOS Main Page Menu

Rate Review System

Rate Review Submission Tab

Uploading the Preliminary Justification

Uploading the Preliminary Justification
(continued)

Uploading the Preliminary Justification
(continued)

Preliminary Justification Submission Confirmation

Email Confirmation of Submission


Successful Email Notification

Accessing Submitted Records

Accessing Submitted Records (Continued)

Accessing submitted records (Continued)

H Accessing submitted records (Continued)


HIOS Record Status Labels
 Pre-attestation
 Review

phase

phase

 Determination

phase

Accessing submitted records (Continued)

Accessing submitted records (Continued)

Accessing submitted records (Continued)

Reviewing Data Submissions

Reviewing Data Submissions (Continued)

Attestation and Deletion

Attestation and Deletion (Continued)

Attestation and Deletion (Continued)

Supplemental Information Requests




For CMS reviews, CMS may request
supplemental information
If supplemental information requested
 Issuers

must respond within ten business days
 Information must be submitted through HIOS

Supplemental Information Request Email

Submission of Supplemental Information Requests

Submission of Supplemental Information Requests
(Continued)

Submission of Supplemental Information Requests
(Continued)

Submission of Supplemental Information Requests
(Continued)

Modify Function






Used by issuers to communicate modifications to
rate increase while a rate is under review
Only for CMS reviews
Issuers must provide a text description of the
modification and may also upload files

Modify Function (continued)

Modify Function (Continued)

Modify Function (Continued)

Rate Review Determinations


Review determinations
 Unreasonable

Rate Increase
 Unreasonable Rate Increase (Modified)
 Unreasonable Rate Increase (Rejected by State)
 Not Unreasonable
 Not Unreasonable (Modified)
 Withdrawn Prior to Determination

Final Justification for Unreasonable Rate Increases



If a rate increase is determined to be
unreasonable
 Issuers

must submit a Final Justification within ten
calendar days of the determination days if
implementing increase



Not required if the issuer withdraws the rate
increase within ten calendar days

Final Justification Submission (Continued)

Withdraw Function

Documenting Changes to Preliminary Justification
Submissions
 Delete

Function: used prior to attestation

 Modify

Function: used between attestation and rate
review determination (CMS reviews only)

 Withdraw

Function: used between rate review
determination and effective date of the increase

CMS Web-Posting of Rate Review Information






Preliminary Justification and rate review
determination posted on Healthcare.gov
CMS will review Preliminary Justification
submission prior to web posting
CMS reviews content of Final Justification
submissions prior to web posting

Issuer Web-Posting of Unreasonable Rate
Increase Information


For all unreasonable rate increase
determinations:
 Issuers

must post the Preliminary Justification and Final
Justification on their website in a prominent location

 Requirement

is satisfied by providing a link to
Healthcare.gov posting

Contacts






Please submit your questions about this training to
[email protected]
Submitted questions will be addressed during CMS
Rate Review User Group calls
User Group calls will take place in August and
September (see training confirmation email for
details)