CurrentAlabama Department of InsurancePolicy 2013-05

Affordable Care Act form filing requirements

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Governs form and rate filing requirements under the Affordable Care Act for health insurance issuers offering individual and small-group coverage in Alabama and describes use of SERFF and CMS HIOS submission processes and deadlines.

Policy Summary

PayerAlabama Department of Insurance

PolicyAffordable Care Act form filing requirements

Policy CodePolicy Policy 2013-05

Change TypeNo material change

Effective DateApr 17, 2013

Next Review Date

Key ActionFile all policy forms and related materials with the Alabama Department of Insurance through SERFF; QHP forms must be submitted by May 30, 2013 and non‑QHP forms at least 30 days prior to use.

SourceLink

POLICY UPDATE CHANGES

No material clinical or coverage changes in this revision.

May 30, 2013QHP SERFF deadline

30 days priorNon‑QHP filing lead time

Apr 1, 2013HIOS window open

Apr 30, 2013QHP exchange filing deadline

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CurrentAlabama Department of InsurancePolicy 2013-05

Affordable Care Act form filing requirements

Customize your policy alerts

Sign up for Alabama Department of Insurance Policy 2013-05 alerts

Get alerted when Policy 2013-05 changes without checking for updates manually.

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Policy Summary

PayerAlabama Department of Insurance

PolicyAffordable Care Act form filing requirements

Policy CodePolicy Policy 2013-05

Change TypeNo material change

Effective DateApr 17, 2013

Next Review Date

SourceLink

POLICY UPDATE CHANGES

No material clinical or coverage changes in this revision.

May 30, 2013QHP SERFF deadline

30 days priorNon‑QHP filing lead time

Apr 1, 2013HIOS window open

Apr 30, 2013QHP exchange filing deadline

2 webinarsHIOS training sessions

Filing and Submission Criteria

Filing and submission criteria

Filing requirements and deadlines for forms and plans:

All health insurance issuers offering individual and small group coverage in Alabama must file all policy forms and related materials with the Alabama Department of Insurance through the System for Electronic Rate & Form Filing (SERFF), whether or not the forms are to be offered inside or outside the Federal Health Insurance Marketplace.

Forms submitted for a qualified health plan (QHP) that will be offered on the Health Insurance Marketplace must be submitted into SERFF by May 30, 2013.

Non‑QHP forms for use outside the Health Insurance Marketplace must be submitted into SERFF at least 30 days prior to use in Alabama (60 days prior to offering for sale when referenced for non‑QHP in CMS guidance).

When submitting form filings in the federal Health Insurance Oversight System (HIOS), identify whether the product/plan is a QHP or a non‑QHP and provide the coverage level for each benefit design (bronze, silver, gold, or platinum); provide separate schedules for each plan design.

HIOS submissions for potential QHPs must include all appropriate templates and supporting documents as identified in the QHP application instructions and will be considered part of the QHP application reviewed by CMS.

HIOS submissions for products/plans not filed as QHPs must include the CMS Prescription Drug Template, Actuarial Value Calculator results, and when appropriate Unique Plan Design supporting documentation and justification, Essential Health Benefit substituted benefit (actuarial equivalent) justification, and formulary inadequate category/class count justification. If pediatric dental and/or vision benefits are omitted, include a description of how those benefits will be provided when sold outside the Marketplaces.

For rate-related filings related to market rating reform, submit the Part I – Unified Rate Review template and Part III – Actuarial Memorandum into HIOS for new or renewal rates effective on or after January 1, 2014 in the individual and small group markets.

Register for CMS Enterprise Identity Management (EIDM) and HIOS, obtain authorization, and request access to the HIOS Form Filing Module and appropriate user roles; contact CMS help desk or Alabama DOI contacts for assistance and training (CMS will host webinars on HIOS Form Filing Module).

Codes and Effective-Date Thresholds

Not applicablemixed

No medical coding or billing codes referenced in this administrative bulletin.

Effective date threshold for rate filings

ThresholdNew or renewal rates effective on or after January 1, 2014 must be submitted into HIOS (Part I Unified Rate Review template and Part III Actuarial Memorandum).

ScopeApplies to rates in the individual and small group markets subject to ACA market rating reform requirements.

Required templatesPart I — Unified Rate Review template and Part III — Actuarial Memorandum must be submitted for affected rate filings.

Required Actions for Issuers

Documentation Required

Form filing requirement and deadlines

File all policy forms and related materials with the Alabama Department of Insurance through the System for Electronic Rate & Form Filing (SERFF) whether or not the forms will be offered inside the Federal Health Insurance Marketplace. Forms submitted for a qualified health plan (QHP) to be offered on the Marketplace must be submitted into SERFF by May 30, 2013; all non‑QHP forms for use outside the Marketplace must be submitted into SERFF at least 30 days prior to use in Alabama.

Submit QHP forms into SERFF by May 30, 2013.
Submit non‑QHP forms into SERFF at least 30 days before intended use in Alabama.

Documentation Required

HIOS submission content requirements

When submitting documents into HIOS identify whether the product/plan is a QHP or non‑QHP, state the coverage level for each benefit design (bronze, silver, gold, or platinum), and provide separate schedules for each plan design. For potential QHPs, file all appropriate QHP application templates and supporting documents; for non‑QHPs submit the CMS Prescription Drug Template, Actuarial Value Calculator results, and any Unique Plan Design or equivalency justifications and pediatric dental/vision descriptions if benefits are omitted.

Key Terms

QHP

DefinitionQualified Health Plan (QHP) — a health plan designated for offering in a Health Insurance Marketplace; QHP filings submitted in HIOS are considered part of the QHP application and reviewed by CMS for PHS Act compliance and QHP certification.

Filing identificationWhen filing in HIOS, issuers must identify whether each product/plan is a QHP or non‑QHP and specify the coverage level (bronze, silver, gold, or platinum).

Supporting materialsFor potential QHPs, file all appropriate templates and supporting documents as identified in the QHP application instructions; for non‑QHPs, include CMS Prescription Drug Template, Actuarial Value Calculator results, and Unique Plan Design or other justifications as applicable.

HIOS

System definitionHealth Insurance Oversight System (HIOS) — the federal document collection repository for form filing submissions and plan/market modules used by CMS for review and QHP certification.

Policy Summary

PayerAlabama Department of Insurance

PolicyAffordable Care Act form filing requirements

Policy CodePolicy Policy 2013-05

Change TypeNo material change

Effective DateApr 17, 2013

Next Review Date

SourceLink

On This Page

Identify QHP vs non‑QHP and coverage level (bronze/silver/gold/platinum).
Provide separate schedules for each plan design offered.
Include QHP application templates and justifications for QHP filings.
Include CMS Prescription Drug Template, Actuarial Value Calculator results, and any required justifications for non‑QHP filings.
If pediatric dental/vision are omitted, include a description of how those benefits will be provided outside the Marketplaces.

Prior Authorization

Rate filing requirement for market rating reform

Submit Part I – Unified Rate Review template and Part III – Actuarial Memorandum into HIOS for market rating reform compliance for new or renewal rates effective on or after January 1, 2014 in the individual and small group markets.

Use the HIOS Integrated Rate Review Module to upload Part I and Part III for any rates effective on or after January 1, 2014.

Note

Registration and access steps

Register in the CMS Enterprise Identity Management (EIDM) portal, complete HIOS registration to receive an Authorization Code, then request access to the HIOS Form Filing Module and appropriate user role via Role Management; contact the CMS help desk or Alabama DOI contacts for assistance if needed.

New users: register at https://portal.cms.gov for an EIDM User ID, then request HIOS access and use the Authorization Code provided.
Existing users: use EIDM account login to access the HIOS tab and request Form Filing Module access via Role Management.
For HIOS access questions contact CMS_FEPS@cms.hhs.gov or 1‑855‑CMS‑1515; for SERFF/form filing questions contact Jennifer Haskell or Robert Turner at the Alabama DOI.

What to submitUse HIOS to submit group and individual policy/contract forms; certificates; riders; endorsements; amendments; Summary of Benefits and Coverage for highest and lowest enrollment benefit packages; and notices of appeals and external review rights.

Submission detailsIdentify how the product/plan will be sold (QHP vs non‑QHP), provide separate schedules for each plan design, and include required templates/supporting documentation per QHP instructions or CMS templates for non‑QHPs.

SERFF

System definitionSystem for Electronic Rate & Form Filing (SERFF) — Alabama’s state filing system through which issuers must file all policy forms and related materials with the Department of Insurance for use inside or outside the Federal Health Insurance Marketplace.

DeadlinesForms for a QHP to be offered on the Marketplace must be submitted into SERFF by May 30, 2013; non‑QHP forms must be submitted at least 30 days prior to use in Alabama.

RequirementAll health insurance issuers offering individual and small group coverage in Alabama must file all policy forms and related materials with the Department through SERFF regardless of marketplace participation.