The proposed rules would establish a temporary state-based reinsurance program, a temporary federal risk corridor program that would protect health plans against inaccurate rate setting and a permanent state-based risk adjustment program.
The AHA made three recommendations on the proposed rule:
• For each of the three risk mitigation programs, all notices regarding methodologies should be made public with a sufficient period of time allowed for review and comment.
• Health plans should be prohibited from passing on to providers the losses from pro rata reduced payments when the reinsurance program in inadequately funded. The AHA said a pro rata approach could put pressure on health plans to recoup losses from providers treating high-cost cases.
• States should comply with federal regulations when collecting encounter-level data.
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