1. 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.

2. 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.

3. 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)

4. 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.

5. 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

6. Fixed Indemnity Plans
Common Structure: base policy either hospital confinement or accident only
Rider options extensive
MO Law: : 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/ 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.

7. 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.

8. Surprise Billing
Federal Update
Missouri Update

9. Questions?

10. Resources Federal Final rule on Short Term Limited Duration plans:
F-STLDI-Final-Rule.pdf
Federal Final rule, court ruling, FAQs on Association Health Plans:
regulations/public-comments/1210-AB85
Federal Excepted Benefits rule:
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