Mississippi Health Exchange Profile
Establishing the Exchange
In October 2011, Mississippi’s elected Commissioner of Insurance Mike Chaney (R) announced that the state would establish a Health Insurance Exchange that would be operated by the Mississippi Comprehensive Health Insurance Risk Pool Association and regulated by the Insurance Department. However, Governor Phil Bryant (R) has opposed the effort to establish a state-based exchange.
The Comprehensive Health insurance Risk Pool Association was created by the Mississippi Legislature in 1991 to operate the state’s high risk pool, which provides coverage for people who want to purchase insurance but cannot obtain it due to health conditions. Mississippi found that the Association has legal statutory authority to operate the Exchange, subject to regulation and supervision by the Department of Insurance. On March 30, 2012, Governor Phil Bryant (R) signed SB 2589, which redefined the number and requirements for the Association’s Board of Directors.
In a Request for Proposals (RFP) released on May 22, 2012, the Risk Pool Association described a strategy to develop and implement the Exchange exclusively using outsourced services with a multi-phased approach. The first phase focused on creating the web portal with shop and compare functionality, with the RFP for this task already awarded. Phase 2 focuses on Exchange functionality for unsubsidized Qualified Health Plans (QHPs), specifically the plan and premium calculation data that will enable consumers to shop, compare, and enroll in a carrier’s plan through the Exchange portal. This phase also includes marketing and outreach, navigator, call center, and other services necessary to support non-subsidized Exchange functions. Phase 3 includes most plan management, eligibility, and enrollment functionality. The selected vendor for this RFP will coordinate with the Mississippi Division of Medicaid, which continues to be responsible for eligibility determination services for Medicaid and the Children’s Health Insurance Program (CHIP). The fourth and final phase is for other supportive services and may be procured together or as a series of individual procurements. Example tasks that may be included in Phase 4 are collection and reporting of claims and encounter data; accountability and performance monitoring; and calculation, processing, and reporting of reinsurance payment and risk adjustment assignment.
Once the Exchange has been implemented, the Association would be responsible for tasks including operation of telephone hotline, maintaining the website for prospective enrollees to compare QHPs, assigning a rating to QHPs, and establishing a consumer outreach program. The Insurance Department would be responsible for plan management, including the procedure for QHP certification.
Structure: The Risk Pool Association operating the Exchange is a non-profit entity that is regulated by the Insurance Department.
Governance: The Risk Pool Association is governed by an 11-member Board of Directors. The Commissioner of Insurance appoints six members, including: two representatives of providers, one representative of businesses with fewer than 100 employees, one representative of agents, and two not associated with a medical profession, hospital, or insurer. Three members are appointed by participating insurers. The final two non-voting, ex officio members are the Chairs of the Senate and House Insurance Committees. The Board of Directors elects one of its members as chairman.
Separate from the Board of Directors of the Association, the Insurance Department established an Exchange Advisory Board to assist the Insurance Department in developing policy, rules, and regulations governing the Exchange. The Advisory Board is comprised of one member from each of the 11 Advisory Board Subcommittees, which represent the following stakeholder groups: consumers, individuals with experience facilitating enrollment in health coverage, advocates for hard-to-reach populations, small businesses and self-employed individuals, large employers, state government agencies, tribes, public health experts, providers, health insurers, and agents or brokers. Two additional Advisory Board Members were selected at-large from the Advisory Board Subcommittees and the Commissioner of Insurance (or his designee) serves as chairman of the Advisory Board.
In the first year, the Commissioner of Insurance appointed the Advisory Board members. Beginning in 2013, the members of the Subcommittees will elect representatives to the Advisory Board. The Commissioner of Insurance will retain appointment of two at-large seats on the Advisory Board and approve the qualifications of other subcommittee applicants.
Though the Exchange Advisory Board meets quarterly, the Subcommittees meet once or twice per month depending partly on the complexity and urgency of the topic area. In addition, the Subcommittees are able to create Technical Advisory Groups to address specific issues, with the approval of the Advisory Board.
Contracting with Plans: In November 2012, the advisory subcommittees on exchange market regulations presented initial plan management recommendations, based in part on subcontractor analyses and stakeholder interviews. The recommendations include that carriers in the small group market should be required to participate in the individual market; carriers can choose plan coverage areas but should cover the same areas inside the Exchange that they do outside the Exchange; carriers should be given flexibility to offer plans at additional metal levels and are expected offer bronze and platinum plans in response to market demand; and plans should not be subject to additional standardization beyond minimum federal requirements.
Risk Adjustment, Reinsurance, and Risk Corridors: In October 2012, a subcontractor analysis concluded that One, Mississippi should defer the risk adjustment model to the federal government initially, but develop a state-based model in subsequent years. The reinsurance program should be deferred to the federal government for three years as well. In November 2012, Mississippi confirmed that federal government is expected to operate both the risk adjustment and reinsurance programs.
Consumer Assistance and Outreach: On May 23, 2012, the Insurance Department released an RFP to develop a statewide community outreach strategy and implement a campaign to inform state residents about the Exchange. In October 2012, the selected vendor launched an outreach campaign targeting small businesses. In addition, this vendor will work with another subcontractor focusing on branding and messaging. In July, the web portal went live, along with a call center provided by the website’s platform vendor. The Association and Insurance Department began soliciting participation from insurance carriers to make their plans available immediately through the portal. Vision and dental policies will be offered on this website in the future.
In June 2012, the subcommittees on outreach, education, adoption, and enrollment submitted recommendations on the Navigator Program to the Advisory Board. They concluded that agents and brokers should not be Navigators. Agents and brokers should be trained and certified, and receive compensation directly from the carriers and not the Exchange. Navigators should also receive comprehensive training and certification, but licensure is too restrictive. A subcontractor analysis also recommended that carriers assign One, Mississippi as their managing general agent and pay a flat fee for each plan sold.
Small Employers Health Insurance Options Program (SHOP): The Risk Pool Association plans to establish a single, statewide exchange for both individuals and the small group market. In addition, employers with less than 50 employees will be eligible for the SHOP, until 2016 when the Exchange is required to increase the threshold to 100 employees. The subcommittees of the Exchange Advisory Board also examined rules for employer participation, considered the value of the defined contribution model, and discussed the benefits of premium aggregation. Their recommendations were compiled and released in a single document in November 2012.
Information Technology (IT): The Risk Pool Association laid out a four stage process to develop the Exchange’s IT infrastructure. The Risk Pool Association awarded the Phase 1 RFP for assistance in creating a health insurance web portal. The Association’s RFP for Phases 2 and 3 was awarded to a single vendor at the end of 2012. In addition, Mississippi intends to allow the federal government to perform eligibility determinations for the Advanced Premium Tax Credit (APTC) and Cost Sharing Reductions (CSR).
Essential Health Benefits (EHB): The Affordable Care Act requires that all non-grandfathered individual and small-group plans sold in a state, including those offered through an exchange, cover certain defined health benefits. Mississippi recommended that the Blue Cross Blue Shield Network Blue, a small group plan, be the state’s benchmark EHB plan.
The Mississippi Department of Insurance received a federal Exchange Planning grant of $1 million in September 2010 and a federal Level One Establishment grant of $20 million in August 2011. The Establishment Grant will be used to conduct public education and outreach programs, plan the Exchange’s IT infrastructure, and continue to coordinate with other public programs such as Medicaid and CHIP. Former Governor Haley Barbour (R) provided a letter of support for the Level One grant application. The Insurance Department anticipates submitting an application for additional federal funds to continue Exchange implementation through 2013.
Despite objections from Governor Phil Bryant (R), on November 14, 2012, Commissioner Chaney issued a declaration letter stating Mississippi’s intent to implement and operate a state-based health insurance exchange. To complete the Exchange blueprint, Mississippi also submitted an application to the U.S. Department of Health and Human Services (HHS), with information about the state’s plans to operate a fully state-based exchange. In late December, Governor Bryant sent a letter to HHS stating that only he has the authority to act on behalf of Mississippi to establish an exchange. On February 7, 2013, HHS rejected the state’s blueprint application.
Additional information about Mississippi’s Exchange from the Department of Insurance can be found at http://www.mid.state.ms.us/pages/health_care_reform.aspx and from the Comprehensive Health Insurance Risk Pool Association at http://www.mshie.org/index.php and from the web portal at http://www.onemississippi.com/index.php .