Colorado Health Exchange Profile
Establishing the Exchange
On June 1, 2011, Governor John Hickenlooper (D) signed SB 11-200 into law, establishing the Colorado Health Benefit Exchange. In January 2013, the Exchange announced that its new name would be Connect for Health Colorado (C4HCO).
Structure: The legislation defines Colorado’s Exchange as a quasi-governmental organization, specifically a “nonprofit unincorporated public entity.”
Governance: The Exchange is governed by a 12-member board. The Board of Directors includes three ex officio, non-voting members (or their designees): the Executive Director of the Department of Health Care Policy and Financing, the Insurance Commissioner, and the Director of the Office of Economic Development and International Trade. The Governor appoints five voting members, though no more than three from the same political party. The President of the Senate, the Speaker of the House, and the Senate and House Minority Leaders each appoint one voting member to the Board. The legislation specifies that all voting members of the Board should possess specific knowledge and skills in areas related to establishing an exchange, such as health benefits administration, health care finance, and/or information technology. It also requires coordination among those making the appointments to ensure the Board includes a broad representation of skill sets and that a majority of voting members are not directly affiliated with the insurance industry. Voting Board members cannot be state employees and no Board members can participate in Exchange activities in which they have a financial interest. Current voting members of Colorado’s Exchange Board of Directors are:
- Gretchen Hammer (Chair), Colorado Coalition for the Medically Underserved
- Richard Betts (Vice Chair), ASAP Accounting & Payroll Inc.
- Stephen ErkenBrack, Rocky Mountain Health Plans
- Dr. Michael Fallon, an emergency-room physician
- Eric Grossman, TriZetto
- Robert Ruiz-Moss, Anthem, Blue Cross and Blue Shield
- Arnold Salazar, Colorado Health Partnerships
- Elizabeth Soberg, UnitedHealthcare of Colorado
- Nathan Wilkes, Headstorms Inc.
The Board of Directors determines and establishes the development, governance, and operation of the Exchange. The Board does not have the authority to promulgate rules nor can it duplicate or replace the duties of the Insurance Commissioner, including rate approval. Instead, the legislation established the joint, bipartisan Legislative Health Benefit Exchange Implementation Review Committee to report up to five bills or other measures each year to the legislative council related to planning and establishing the Exchange. The Committee, comprised of 10 legislators, is also charged with reviewing the financial and operational plans of the Exchange and grants for which the Board has applied.
In December 2011, the Legislative Health Benefit Exchange Implementation Review Committee confirmed the Board’s nominee for Executive Director of the Exchange.
The Exchange Board began meeting regularly in July 2011. At the first Board meeting consumer advocates voiced concerns that a majority of the Board has close affiliations with the insurance industry, which would be a violation of the legislation establishing the Exchange. However, no action was taken to change the composition of the Board. The following month, the Health Benefit Exchange Implementation Review Committee held its first meeting to begin initial reviews of the operational and fiscal plans of the Board.
In January 2012, the Exchange Board submitted its first annual report regarding planning and establishment activities of the Exchange to the Governor, the Senate Health and Human Services Committee, and the House Health and Environment Committee. Given the extensive list of policy questions facing the Exchange, the Board adopted a general process to address policy issues and a framework for organizing policy issues.
Contracting with Plans: The Exchange will function as a clearinghouse that “foster[s] a competitive marketplace for insurance and shall not solicit bids or engage in the active purchasing of insurance. All carriers authorized to conduct business in [the] state may be eligible to participate in the Exchange.” In October 2012, the Exchange issued a Request for Information for Provider Directory Services soliciting a subcontractor to compile provider data on health plans sold in the Exchange. The data will be used to populate a search tool that will help consumers compare and select qualified health plans (QHPs). The Exchange has also begun considering how to display quality information to consumers about QHPs.
C4HCO will partner with the Division of Insurance (DOI), the Department of Public Health, and the Department of Health Care Policy and Finance (HCPF) to perform plan management functions. Carriers must apply through the System for Electronic Rate and Form Filing (SERFF) and must offer at least one silver-level QHP and one gold-level QHP. The deadline for plan submission was May 15, 2013; ten carriers filed to offer plans on the individual market and six carriers submitted plans for the small group market. The DOI is currently reviewing the plans to ensure compliance with the essential health benefits requirement and other state and federal requirements and will conclude by July 31. C4HCO will make final certification determinations and will send participation agreements to carriers by early September.
Risk adjustment, Reinsurance, and Risk corridors: Colorado has decided to allow the federal government to administer the risk adjustment programs for the Exchange at least until December 2015.
Consumer Assistance and Outreach: Since opening, the Exchange has hired staff to manage outreach activities and engaged in an extensive outreach campaign running from May through September 2012, which included meeting with stakeholder groups across nine cities. In October 2012, the Colorado Exchange released a Request for Information for Marketing and Outreach to solicit subcontractors to provide the state assistance with market research and executing a statewide marketing campaign and awarded two contracts in December 2012. In May 2013, Colorado launched a $2 million public awareness campaign, including television, print, radio, and billboard advertisements in English and Spanish. The campaign, which will last for two months, also aims to establish C4HCO on various social media platforms, including Twitter, Facebook, LinkedIn, and YouTube. Colorado is planning a second outreach effort closer to the start of open enrollment. In May 2013, the Exchange launched the C4HCO website, which includes a subsidy calculator, and established a toll-free phone number.
C4HCO will also rely on carriers to conduct marketing and outreach activities and requires that all carrier QHP marketing materials include the C4CHO logo. All materials must be approved by the C4HCO marketing team prior to publishing, to ensure compliance with the Connect for Health Colorado Logo Style Guide. Carriers are also required to submit marketing materials to the DOI through SERFF, and must do so by June 30, 2013.
C4HCO will establish the Connect for Health Colorado Assistance Network (Assistance Network) to provide assistance to consumers seeking health coverage through the new marketplace. In February 2013, the Exchange issued a Request for Proposals (RFP) for community-based organizations to serve as Assistance Sites and Regional Assistance Hubs in the individual market, the SHOP, or both. Regional Hubs will provide support, supervision, and training for Assistance Sites throughout their region, as well as assist C4HCO with communications efforts throughout the Assistance Network. Assistance Sites will hire, train, and supervise Health Coverage Guides, who will perform in-person education and application assistance services. In June 2013, C4HCO announced the 57 groups that have been selected to serve as Regional Hubs and Assistance Sites. The organizations will receive a total of $17 million in federal and private grant funding. Health Coverage Guides will be hired in June and July, and training will take place in August and September.
C4HCO will train and certify staff and volunteers, who currently work at organizations selected by C4HCO and the HCPF, to become Certified Application Counselors (CACs). CACs will help individuals and employers apply for coverage in a QHP through the Exchange and through other insurance affordability programs. C4CHO will establish a timeline for program implementation as well as training requirements.
In addition, the Board approved certifying brokers to sell through the Exchange with compensation set by the carriers that is the same inside and outside the Exchange. Brokers will participate in both the individual and SHOP Exchanges; however, individuals and small businesses will not be required to use a broker. Broker certification is expected to begin in August 2013.
The Exchange has also begun to build a contact center that will provide assistance to individuals and small employers with enrollment through all available channels including website, telephone, and mail. C4HCO expects to train around 100 customer service representatives to provide information at different levels. Some will be trained to enroll people in coverage, and all representatives will direct individuals to Health Coverage Guides in the community if requested. In April 2013, C4HCO selected a location for the customer service center and signed a lease with the management company. The Exchange will hire all call center staff by August 2013 and will complete training by September.
Small Business Health Options Program (SHOP) Exchange: The Exchange Board agreed with the Department of Insurance recommendation to limit the size of the SHOP Exchange to employers with 50 or fewer employees in 2014 and 2015. The Board also approved the creation of four new advisory groups including, health plan, individual experience, SHOP, and outreach and communication. The SHOP Exchange advisory group began meeting in June 2012 to address the consumer interface portal and the work flow that will guide employees and employers through the plan selection process. The SHOP advisory group will also examine the business processes and technologies needed to support broker participation in the Exchange.
The Board recommended that, at an administrative level, there be one Exchange for both the individual and SHOP Exchange. This approach will minimize ongoing operational costs, gain efficiencies of scale and ensure appropriate attention to each Exchange. However, the Board recommended the state keep the risk pools separate and revisit the decision at a later date. The Board also agreed to allow employers to select from four options in the SHOP Exchange; employers can choose a single QHP for all employees, choose a panel of QHPs from a single carrier that represent a range of actuarial values, offer any plan within a single metal tier, or offer any plan that is offered in two adjacent metal tiers. The Board approved a recommendation for the Exchange to establish minimum employer contribution and employee participation requirements that resemble the outside market.
Information Technology (IT): The Exchange Board has created an Information Technology and Implementation committee that meets weekly to provide guidance on strategic decisions such as IT investments, acquisition of services and procurement strategy. The state plans to pursue technology solutions that will deliver the minimum requirements of interoperability between the Exchange and state systems and business processes. The state plans to upgrade its current Medicaid and Children’s Health Insurance Program (CHIP) eligibility and enrollment systems, which will then interface with the state Exchange.
In January 2012, the Exchange released multiple Requests for Proposals (RFPs) soliciting vendors to provide a comprehensive web portal solution and call center operations and to provide project management services. In May 2012, the Board identified a subcontractor to begin the development, implementation, operation, and maintenance of the IT systems. In August, the Exchange issued an RFP for Independent Verification and Validation Services for the IT systems. The Exchange intends to begin system testing in January 2013, piloting the SHOP Exchange in May, piloting the Individual Exchange in July, and then making the entire system live October 1, 2013. As of June 2013, five of six IT system releases had been delivered and successfully tested.
Colorado is also participating in the “Enroll UX 2014” project, which is a public-private partnership creating design standards for exchanges that all states can use.
Financing: SB 11-200 prohibits Colorado from financing the Exchange using the General Fund. In March 2013, the Board approved a recommendation to assess a carrier administrative fee of 1.4% of premium for products sold on the Exchange in 2014. In May 2013, the General Assembly passed HB 13-1245, establishing three funding mechanisms for C4HCO that will supplement the revenue generated by the assessment. HB 13-1245 imposes a broad-based assessment on carriers for individual and small group insured lives in the state. The assessment, which will be up to $1.80 per policy per month, will last for a maximum of three years. The law also shifts excess reserves to C4HCO from CoverColorado, the state’s high risk pool that will close in 2014. C4HCO will receive $15 million from CoverColorado in 2014 and $8.5 million in 2015. In June 2013, the Board set a $0 market assessment for medical and dental plans in 2014, determining that funds beyond those being transferred from Cover Colorado would not be needed for the first year of operations. C4HCO’s annual operating budget is expected to be around $25 million.
Essential Health Benefits (EHB): The Affordable Care Act (ACA) requires that all non-grandfathered individual and small-group plans sold in a state, including those offered through the Exchange, cover certain defined health benefits. After soliciting comments from stakeholders and reviewing EHB options, the Exchange Board announced a draft recommendation for Colorado’s largest small group plan, a Kaiser HMO plan. The Board also made a preliminary recommendation to select Colorado’s Child Health Plan Plus for supplemental pediatric dental benefits.
The legislation prohibits appropriations of state funds for the Exchange, though Colorado can apply for federal grant funding. The Colorado State Office of the Governor received a federal Exchange Planning grant of approximately $1 million in 2010. In February 2012, the state received a Level One Establishment grant for $17.9 million to build the operational staff and consulting support necessary to progress on key design requirements of the Exchange. In September 2012, Colorado received a second Level One grant of $43.5 million to support technology development, specifically in order to meet deadlines for certification, testing, and deployment of systems and operations. In July 2013, Colorado received a Level Two Establishment grant for$116.2 million to support technology enhancement, develop the consumer center and education campaign, design a quality improvement program, and fund the Connect for Health Assistance Network.
Colorado, along with nine other states, is receiving technical assistance from the Robert Wood Johnson Foundation through the State Health Reform Assistance Network; this assistance includes help with setting up health insurance exchanges, expanding Medicaid to newly eligible populations, streamlining eligibility and enrollment systems, instituting insurance market reforms and using data to drive decisions.
On December 7, 2012, Colorado received conditional approval from the U.S. Department of Health and Human Services (HHS) to establish a state-based exchange. Final approval is contingent upon the state demonstrating its ability to perform all required Exchange activities on time, complying with future guidance and regulations, and on the state’s ability to collect forms as part of the QHP certification process. Additional information about the Colorado Health Benefit Exchange can be found at http://www.connectforhealthco.com/