CMS has confirmed that Georgia’s Section 1332 state innovation waiver, which changes the Affordable Care Act exchange model, is complete. The waiver will now move into a public comment period. As it currently stands, the state innovation waiver would shift Georgia’s individual health insurance marketplace from HealthCare.gov to its Georgia Access Model. It would also pursue a reinsurance program through tiered coinsurance.
The state expects the reinsurance program to stabilize the market, reducing premiums by over ten percent. The proposal projected that the Georgia Access Model would increase individual health insurance market enrollment by 25,000 and, as a result, bring down premiums by 3.5 percent. The cost to fund this project would be $144 million for its starting year 2022.
The Georgia Academy sent comments to Governor Kemp when the proposal was first up for review, and again has submitted comments to CMS. A summary of those comments is below:
While we appreciate that this proposal will not interrupt coverage with patients with pre-existing conditions, we are concerned about allowing non-ACA compliant plans into Georgia. Furthermore, removing Georgia from the healthcare.gov platform would penalize Georgians looking for a one-stop marketplace to compare and select insurance plans, forcing them to rely on scattershot network of web-brokers and other actors that may take into account Georgians’ financial or health needs. Under this arrangement, Georgia would be the only state nationwide to remove itself from this marketplace.
The current proposal to allow Georgians to buy extended, short-term health insurance (non-ACA compliant) is a step back to the days when companies sold low-value insurance policies that subjected our patients to catastrophic medical bills and medical bankruptcy.
The current proposal would allow exempt these non-compliant plans from Affordable Care Act consumer protections such as covering essential benefits, which include prescriptions, laboratory tests, hospitalization, and maternity care. It would allow plans to establish caps once again on annual benefits. Limiting benefits can expose patients to extraordinarily high out-of-pocket costs, particularly for people who have chronic or life-threatening conditions that require costly treatment, close monitoring and ongoing medication.
Equally troublesome, these plans further destabilize the individual market by drawing young, healthy people away from meaningful, comprehensive coverage that meets ACA standards. Allowing the healthy to gamble with low-quality insurance will also raise ACA-compliant plans’ premiums, putting better coverage beyond the reach of millions of the sickest Americans.
The Georgia Academy has stood with the American Academy of Family Physicians in steadfastly calling for policies that ensure all Americans have access to affordable, meaningful health insurance. Georgia policies should support patient-centered insurance reforms that prohibit insurers from selling plans that fail to provide meaningful coverage.
Any plan allowed to be sold to Georgians in our state should have these minimum essential health benefits:
At a minimum, these would include items and services in the following benefit categories:
- Ambulatory patient services
- Emergency services
- Maternity and newborn care
- Mental health and substance use disorder services, including behavioral health treatment
- Prescription drugs
- Rehabilitative and habilitative services and devices
- Laboratory services
- Preventive and wellness services and chronic disease management
- Pediatric services, including oral and vision care
In addition to requiring coverage for essential health benefits, all proposals or options will ensure that primary care is provided through the patient’s primary care medical home. To foster a longitudinal relationship with a primary care physician, all proposals or options will provide the following services independent of financial barriers (i.e., deductibles and co-pays) if the services are provided by the patient’s designated primary care physician:
- Evaluation & management services
b. Evidence-based preventive services
c. Population-based management
f. Basic mental health care
The leadership will continue to monitor the progress of this CMS waiver and inform the membership when news develops.