Hot Topics II Angela Nelson, MO DIFP Mary Mealer, MO DIFP Mary Nugent, CMS Ron Kotowski, Moderator Please use this as the opening slide of your presentation.

Short Term Limited Duration Plans Association Health Plans HOT TOPICs II: Short Term Limited Duration Plans Association Health Plans Fixed Indemnity Plans Surprise Billing Thank you for joining us today. Our agenda covers MACRA, Short Term LTC Model And Model 171.

Short Term Limited Duration Plans Federal Law MO Law Trends in MO filings Common Policy Designs/Exclusions Riders Renewability Congress, in an attempt to reduce medical spending and increase consumer awareness of medical care usage and costs, passed MACRA. In this session we will discuss… (read the slide)

STLD: Renewability Options in MO Filings: Renewability Rider: Automatic renewal -- up to 5 renewals Pre-existing under previous plan do not apply to renewal No evidence of insurability required Reissue Rider Complete 2 applications at time of original One covers for first 6 months; second application issued for “second” term Reissuance of policy without underwriting/health questionnaire Previous policy’s benefit levels carry over to new policy term Consecutive Rider Continuous, uninterrupted coverage Pre-existing is modified to look back of only 24 months (not 60) and pre-existing under first policy will not be under second Contestability provision applies from the effective date of first policy.

Association Health Plans Department of Labor (DOL) change to definition in ERISA Court decision DOL notices after court decision State reactions Missouri Bulletin Nevada Bulletin

Fixed Indemnity Plans Common Structure: base policy either hospital confinement or accident only Rider options extensive MO Law: 376.998: prohibits excepted benefit plans from combining coverage or changing payment methodology to extent that “combination or coverages and benefits would otherwise meet the definition of a health benefit plan.” MACRA becomes effective for plans issued on or after 1/1/2020. MACRA prohibits the sale of Medigap plans C, F and hi deductible F to newly eligibles after 1/1/2020. This prohibition makes the first dollar of care the responsibility of the insured. Congress envisioned this first dollar requirement would encourage consumers to think about medical care before receiving it as a means to control costs…is it medically necessary or convenience? Am I receiving care at the right setting in order to use resources wisely? Since MACRA prohibits the sale of C, F and F Hi Deductible after 1/1/2020 to Newly Eligibles, the model had to identify new guaranteed issued plans which are Plans D and G and High Deductible G. High Deductible G was created to replace High Deductible F. Please note, those eligible for Medicare prior to 1/1/2020 can continue to purchase all plans, even C and F or purchase the newly created Plan G High Deductible. Definition of Newly Eligible Medicare Beneficiary: those who have attained age 65 on or after 1/1/2020 or first become eligible for Medicare due to age, disability or end-state renal disease on or after 1/1/2020.

Fixed Indemnity: Unusual Riders: Rainy Day Fund: additional benefits when benefit frequency limitation met. Available each year and “extends” the coverage on exhausted benefit. Insured starts each year with at least the initial rainy day fund amount. Company will use funds to pay claims until exhausted. If all funds not used year end, roll over. Injury Free Benefit: if no claims incurred (except wellness) company will pay stated amount. Office Visit Free Benefit: pays out of pocket amount if visit charged separately from treatment. Value Added Service: care consulting services which include assistance with appointments, information on providers, etc.

Surprise Billing Federal Update Missouri Update

Questions?

Resources Federal Final rule on Short Term Limited Duration plans: https://www.cms.gov/CCIIO/Resources/Files/Downloads/dwnlds/CMS-9924- F-STLDI-Final-Rule.pdf Federal Final rule, court ruling, FAQs on Association Health Plans: https://www.dol.gov/agencies/ebsa/laws-and-regulations/rules-and- regulations/public-comments/1210-AB85 Federal Excepted Benefits rule: https://www.ecfr.gov/cgi-bin/text- idx?SID=892dbd2b94fb54246499c3d455bb811d&mc=true&node=se45.1.148 _1220&rgn=div8