The Choice and Competition Coalition (CCC) has advocated that HHS issue state requirements for implementing exchanges that are timely, simple, and complete. Exchanges should provide consumers with a wide array of health insurance choices. We are pleased that the Administration has issued this rule which provides significant state flexibility in designing competitive, market-based exchanges.
However, it is clear that there is still much to finalize in a short amount of time for states and other stakeholders to be ready for open enrollment in October 2013.
Forthcoming guidance will be critical for all stakeholders to know how HHS will determine whether state exchanges are operationally ready by the end of this year and how HHS will operate an exchange in states where necessary. In the immediate future, we are hopeful that HHS will clarify the criteria for “conditional approval” and a simple application process so willing states can operate exchanges serving individuals and small businesses.
For small business exchanges to work effectively, the CCC believes it is critical that employers continue to have the option of keeping their employees together when selecting qualified health coverage. Unfortunately, the final rule requires small business exchanges, at a minimum, to default to a complex, new system that disbands employer groups. The CCC believes a SHOP designed for success on day one should allow employers participating in small business exchanges to be provided options for making health coverage available to their workers - including the ultimate ability to choose which plan or plans that they will offer to their employees.
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