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Hot Topics II

Hot Topics II. Angela Nelson, MO DIFP Mary Mealer, MO DIFP Mary Nugent, CMS Ron Kotowski, Moderator. HOT TOPICs II: Short Term Limited Duration Plans Association Health Plans Fixed Indemnity Plans Surprise Billing. Short Term Limited Duration Plans Federal Law MO Law

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Hot Topics II

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  1. Hot Topics II Angela Nelson, MO DIFP Mary Mealer, MO DIFP Mary Nugent, CMS Ron Kotowski, Moderator

  2. HOT TOPICs II: • Short Term Limited Duration Plans • Association Health Plans • Fixed Indemnity Plans • Surprise Billing

  3. Short Term Limited Duration Plans • Federal Law • MO Law • Trends in MO filings • Common Policy Designs/Exclusions • Riders • Renewability

  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: 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.”

  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: 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

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