Dental & ACA Implementation Presented by: NADP Health Care Reform Task Force & Staff Date: Tuesday, September 11, 2012

Sponsors Gold

United Concordia Companies, Inc.

Silver Heartland Dental Care, Verisk Health, DenteMax,

Stratose, Coastal Dental, Dentalplans.com

Bronze Emblem Health, Ameritas, PPO USA, Delta Dental of CA,

Aspen Dental Mgmt.

Other Sponsors Pacific Dental Services

• NADP Priorities • ACA Federal Guidance • ACA Calendar • State Exchanges • Federally-facilitated Exchanges • Member Perspective • Dental Plan Calendar • State Essential Health Benefits • Fees & Taxes • NADP Resources

AGENDA 3

• Equitable Treatment • Allowing separate medical and dental policies combined to

meet the EHB outside Exchanges • Exchanges

• Dental Appropriately Included • Essential Health Benefit

• Valued & Affordable Pediatric EHB • Assessments on Plans

• Tax Assessment & Exchange Fees • Oral Health

• Support ACA Oral Health Provisions

NADP PRIORITIES 4

EQUITABLE TREATMENT

• HHS acknowledged issue in Exchange Regs • TBD in EHB Regs (?)

• NAIC: Mkt. in & out of Exchange should be same

• ADA, Business & Congressional Support

• Stabenow leadership continues

• Meeting with White House • Letters from Senators to

White House • Pursuing ADA comment &

potential NAIC support • Prep for alternative action if

decision is unfavorable

5

KNOWN NADP ACTIONS

FEDERAL GUIDANCE

• EHB Benchmark Guidance • HIX Regulations

• No Limits • Relevant QHP certification

criteria apply to QDP • ST Decides on Transparency of

Dental • HIX Blueprint for States • SHOP Applications--DRAFT • Collection of Data—DRAFT • Market Reforms

• EHB Regulations including Cost Sharing

• Additional HIX Regs • AV Specifications • Plan Management / Dental

Certification Criteria (if Fed.)

• OPM: Multi-State Plans • IRS: Plan Assessment

6

GUIDANCE RELEASED TO BE RELEASED “SOON”

ACA TIMELINE 7

2012

• 3Q: State to choose EHB benchmark

• Nov. 16: State to Submit HIX Blueprint to CCIIO

2013

• Jan: CCIIO to Announce Approval of State Blueprints

•1Q: CCIIO & States Qualify Health and Dental Plans

•Oct 1: Enrollment begins in HIX

2014 • Individual Mandate in Effect • HIX Coverage Starts • Assessment Fee Collected

2015 • HIX to be Self Sufficient

2016 • Small Employer Defined as

100 & Fewer—All States

2016 • HIX Can Allow Large

Employer

2017 • Excise Tax On High Cost

Insurance (Dental Exempt)

EXCHANGE MODELS 8

Green = State Base Exchange Yellow = State & Federal Partnership Red = Federally-facilitated Exchange

STATE EXCHANGES 9

MT

AR

ND

NV

OR

TX AK

AL

CO

CT

FL

ID

LA

GA

IL IN

KS KY

ME*

MD

MN

MO

MS

NE

NM OK

SC

SD

UT* VA

WA

WI

WV

AZ*

HI

WY

IA

DE

TN

NH

CA

NC*

OH

MI

PA

NY

VT

MA

NJ

9

RI

DC

QHP CERTIFICATION STANDARDS 10

Apply (partial) Child Only Plans Individual Policies No lifetime or annual max No Discrimination Use of Community Providers Processes for Payment, Enrollee Termination, etc. Licensing

Marketing

Exchange User Fees

Modify Cost Sharing Limits Quality Improvements Rate Information & Justification Network Adequacy Provider Information Enrollee Information

Do Not Apply Actuarial Values Risk Adjustment

Same premium inside & outside Exchanges

Accreditation

Abortion Coverage

Prescription Drug Coverage

Federally-facilitated Exchanges SHOP Impacts Outside of Exchanges

FEDERAL ACTIVITIES 11

FEDERALLY-FACILITATED EXCHANGES

• Additional Coverage: Adult & Non-pediatric Dependent

• Dental Plan Conditional Approval

• Offer not Purchase of Pediatric Dental

• Portion of Subsidy to Dental Plan

• FFE to use HIOS as Data Hub and coordinate with SERFF

• Dental Choice @ Front • Dental Benefit Compared

Whether Embedded or Separate

• External HIX Portals Linked • Provider Directory &

Summary of Coverage Stays on Carrier’s Site

• Consumer Cost Estimator Later

12

BENEFITS / ENROLLMENT PLAN COMPARE / WEB

FEDERALLY-FACILITATED EXCHANGES

• Undetermined • OOP Coordination • Age of Pediatric • Metal Levels AV Calculator for Dental

• Rating Tiers/Family Grouping TBD

• How will Carriers be Ranked?

13

BENEFITS / ENROLLMENT PLAN COMPARE / WEB

SHOP

• Policyholder Will be Employer • Limited Rating Factors

• No Experience • States Set Geographic

Rating Areas • Small Employer Definition

Defaults to ST (until 2016) • Employer Address Used for All

Employees • Rate Each Year as “New”

Business

14

KNOWN--RATING KNOWN • Employers Can Limit Offer

to Employee Only • External Sites Link to FFE -

Facilitate Enrollment • 85% Applications Through

Broker Electronically • “Offer“ of Dental Not Seen

as Mandatory Purchase

SHOP

• Employer/Employee Choice (Leaning Employee)

• Use of “Sheet Rating” for Premium Estimates

• Rating Tiers • Will “Child-only” Policies

be Required

15

ISSUES TBD

• Equitable Treatment -- What IF no clarification

• Duplication of Coverage • Impact 22.9 million children covered in small group

market • Coordination Issues

• Benefits Inside and Outside Exchange Coverage Medical & Dental Outside Exchange Coverage

• Out-of-Pocket Maximums • Are Child-only Policies Required? • Impact of Exchanges -- 50 or 100?

PRIVATE MARKET 16

Member Perspective 17

NADP

Health

Care

Reform

Task

Force

Chris Swanker, Guardian

Theresa McConeghey, Principal

Kirk Andrews, UHC

Jeff Album, Delta of CA

Gail Garcia, Ameritas

PLAN PREPARATION 18

2012

• 3Q: State to choose EHB benchmark

• Nov. 16: State to Submit HIX Blueprint to CCIIO

2013

• Jan: CCIIO to Announce Approval of State Blueprints

•1Q: CCIIO & States Qualify Health and Dental Plans

•Oct 1: Enrollment begins in HIX

2014 • Individual Mandate in Effect • HIX Coverage Starts • Assessment Fee

Prep for Assessment Fee (2013 Base Yr)

Prep for HIX: Staffing in Products, IT, Call Centers, Compliance, Training…

Prep for ST or FED QDP/QHP Cert.

Prep and File Exchange Policies

Broker/Agent Training

IT Testing

Potential HIX Fee

Unknowns: Summary of Coverage, Notice of MEC…

New Enrollees

Continued Implementation Upgrades & Changes

Prep for 2015-2018 Market Changes

• CA: Dental – CHIP/Healthy Families, Health – Kaiser Small Group HMO • DC: Dental cost est. $4 PMPM (Benefit FEDVIP/Pricing FEHBP) • MD: Dental cost est $6/7 PMPM (Benefit FEDVIP) • NY: Dental Benchmark includes Adult Dental

• Will that mean adult dental as part of EHB? • UT: Dental – Limited to 2 checkups for ages 3-18 Health – High deductible State Employee Plan • VT: Dental – CHIP, Health – BCBS VT • VA: Dental – CHIP/Smiles for Dental, Health – Anthem Small Group PPO

Considering EHB w/ Dental: AL, AZ, CT, DE, MD, ME, MI, MS, NE, NV, OR,

TX, WA Considering EHB Overall: AR, CO, NV, NC, TN

STATE EHB BENCHMARKS 19

FEES & TAXES 20

- ACA Insurer Assessment Applies to Dental (2014 est. @ 2.16% ) - Dental Subject to Exchange Fees - Dental Exempt from Cadillac Tax

- Ability to Collect Insurer Assessment on 2013 Premium - Level of Exchange Fees & How Applied to Dental

- Exchange Fee for Dental reflecting smaller premium

- Outreach to IRS for Clarification on Assessment - FFE Discussion of FFE Exchange Fees *Plans: Lobbying on Dental Portion of Exchange Fees

Fees & Taxes

21

NADP 2012 Revised Estimate ACA’s Insurer Assessment

2013 2014 2015 2016 2017 2018 2019 2020

Private health Insurance (billions)1 $ 926.90 $ 1,013.70 $ 1,076.70 $ 1,141.00 $ 1,200.30 $ 1,251.00 $ 1,324.70 $ 1,402.00

Full-Insured Plans2 $ 370.76 $ 405.48 $ 430.68 $ 456.40 $ 480.12 $ 500.40 $ 529.88 $ 560.80

Fee to be Collected3 (Pd following year) $ 8.00 $ 11.30 $ 11.30 $ 13.90 $ 14.30 $ 14.90 $ 15.78 $ 16.70

Fee as a % of premium (all carriers) 2.16% 2.79% 2.62% 3.05% 2.98% 2.98% 2.98% 2.98%

IMPORTANT: This estimate is the low end of a range which does not consider: • exemptions within PPACA for companies by size or for types of insured's, • regulations defining net premium on which the fee is to be calculated, • how the tax may be distributed across fully insured plans, nor • shifts in the mix of fully insured and self-insured plans over time.

NOTE: GAAP and STAT accounting standards apparently differ on whether an assessment can be collected on premium in one year and paid in the following year. This issue is being raised with Treasury for guidance as part of their 2012 rulemaking process.

1 Health spending projections based on 2009 version of the National Health Expenditures released in January 2011. 2 40% of all employees with health benefits are covered by fully insured plans. Source: Kaiser/HRET Survey of Employers-Sponsored Health Benefits, 2011. 3 Tax to be collected in billions.

• Issue Briefs & Memos • List of Dental in ST EHBs & Exchanges • GR/SEW Grid • IB: Equitable Treatment • IB: Certification of Qualified Dental Plans • IB: Premiums & AV Levels • Memo to OPM: Multi-State Plans • Memo to CCIIO: Plans Offering Coverage on Exchanges • Overview of Federal Meetings: White House, CCCIIO, etc. • White Paper: Roadmap of Including Dental into Exchanges • Estimates of Benchmark Dental Premiums & Assessment

• Comments • Fed: SHOP HIX Applications, Data Collection, EHB Benchmarks • ST: Exchange & EHB • NAIC: Response to White Papers & SERFF

NADP RESOURCES 22

Jeff Album, Delta of CA

Kirk Andrews, UHC

Forrest Flint, HealthPartners

Gail Garcia, Ameritas

Donna Kasian, DentaQuest

Natasha Khouri, Aetna

23

NADP HCR TASK FORCE Theresa McConeghey, Principal

Ted Osthelder, Wellpoint

Courtney Ransom, MetLife

Jon Seltenheim, UCCI

Gene Sherman, Starmount

Chris Swanker, Guardian

THANK YOU nadp.org