Connecticut Health Exchange Profile
Establishing the Exchange
On July 1, 2011, Governor Dan Malloy (D) signed SB921 (Public Act 11-53) into law establishing the Connecticut Health Insurance Exchange. Legislation altering the composition of the Exchange Board passed in June 2012. In December 2012, the Exchange announced that its new name would be “Access Health CT.”
Structure: The legislation defines Connecticut’s Health Insurance Exchange as a quasi-governmental organization, specifically “a body politic and corporate, constituting a public instrumentality and political subdivision of the state…which shall not be construed to be a department, institution or agency of the state.”
Governance: The Exchange is governed by a 14-member board including six ex-officio members. Elected officials appoint eight of the twelve voting members. The Governor appoints two members, one with expertise in individual health insurance coverage and one with expertise in small employer health insurance coverage; the President pro tempore of the Senate appoints an expert in health care finance; the Speaker of the House of Representatives appoints someone knowledgeable in health care benefits plan administration; the Majority Leader of the Senate appoints an expert in health care delivery systems; the Majority Leader of the House of Representatives appoints a health care economist; the Minority Leader of the Senate appoints a person with expertise in health care access issues facing self-employed individuals; and the Minority Leader of the House appoints someone knowledgeable in barriers to individual health care coverage. The four voting ex officio Board members (or their designees) include, the Commissioner of Social Services, the Special Advisor to the Governor on Healthcare Reform, the Healthcare Advocate, and the Secretary of the Office of Policy and Management; non-voting ex officio Board members (or their designees) include, the Insurance Commissioner and the Commissioner of Public Health.
Board members cannot have affiliations with any of the following entities while on the Board: an insurer, an insurance producer or broker, a health care provider, a health care facility or clinic, or trade associations for these entities. Also, members cannot be health care providers receiving compensation for services nor have ownership interest in a professional health care practice. These conflicts of interest provisions apply to Exchange staff as well as the Board, though Board Members are also prohibited from working for a health care carrier that offers a plan through the Exchange for the year after serving on the Board.
Current appointed Board members are:
- Nancy Wyman (Chair), Lieutenant Governor
- Mary Fox, formerly with Aetna Product Group
- Robert Scalettar, MD, formerly with Anthem Blue Cross Blue Shield
- Bob Tessier, Connecticut Coalition of Taft Hartley Health Funds
- Cecilia Woods, Permanent Commission on the Status of Women
- Grant Ritter, Schneider Institute for Health Policy at Brandeis University
- Paul Philpott
The Board hired its first Exchange CEO in June 2012 after holding meetings for nearly a year prior. Consumer groups continue to express concerns that a number of Exchange Board members have close affiliations with the insurance industry while consumers and small businesses remain under represented.
The Board’s work has been informed by the Health Insurance Exchange Planning Committee, within the Office of Policy and Management, which meets bimonthly. Extensive subcontractor analyses of the insurance markets, carriers, information technology infrastructure, and uninsured and underinsured residents of the state have also been completed. The Health Insurance Exchange Planning Committee conducted public forums and stakeholder meetings through the spring of 2011 and selected a vendor to complete research and market analyses and develop an effective outreach strategy.
Connecticut’s Exchange legislation requires the Exchange Board to report annually to the Governor and General Assembly on a variety of issues. The Board must also make any necessary legislative recommendations to reduce the negative impact on the sustainability of the Exchange. The first annual draft report by the Exchange Board to the General Assembly was released in January 2012 and updated in February.
Advisory committees established in March 2012 meet monthly to assist in Exchange policy development and evaluation in four key areas: health plan benefits and qualifications; Small Business Health Options Program (SHOP); consumer experience and outreach; brokers, agents, and Navigators.
Contracting with Plans: The Exchange has the legal authority to function as an active purchaser, “limit[ing] the number of plans offered, and us[ing] selective criteria in determining which plans to offer, through the exchange, provided individuals and employers have an adequate number and selection of choices.” In October 2012 however, the Board decided to allow any (Qualified Health Plan) QHP meeting selected criteria to be sold in the Exchange for 2014. The Exchange acknowledges that for 2015 and later, they can still opt for a competitive bidding process and develop selective contracting criteria.
The legislation does not describe the contracting requirements, but requires the Board to adopt written procedures to explain requirements for certification of qualified health plans. At a minimum, carriers participating in Access Health CT must offer one standard plan for each of the bronze, silver, and gold tiers. Issuers in both exchanges may opt to offer a standard plan for the platinum tier, and issuers in the Individual Exchange may choose to offer a catastrophic coverage plan. Plans participating in the individual Exchange must submit three silver alternative standard plans that reflect cost sharing reductions, two zero cost-sharing plans for American Indians, and a child-only plan. Plans offered within the Exchange must charge the same premium as when offered outside the Exchange, whether sold by an insurance producer or directly by the carrier. Carriers must publicly justify any increase in premiums of plans offered within the Exchange.
In November 2012, the Exchange released an initial QHP solicitation for participation in the Exchange and received nine letters from issuers stating their intent to offer medical or dental coverage on the Exchange. In March 2013, the Board released approved standard plan designs for the metal tiers that each QHP must offer as well as two non-standard plans per metal-level tier, including a catastrophic plan. Access Health CT released a final QHP solicitation on April 6; QHP certification applications are due May 15 and Access Health CT expects to begin certifying plans on July 31. Issuers may choose to participate in the individual Exchange, the SHOP Exchange, or both. Issuers meeting certification standards will be certified to participate in the Exchange for two years; however, QHP benefits and plans must be filed and certified annually. The Connecticut Insurance Department (CID) is responsible for reviewing and approving rate filings and rate increases. Issuers may rate based on age and geography, but tobacco rating will be prohibited in the individual market for 2014.
Provider networks for each QHP must meet Utilization Review Accreditation Commission (URAC) or National Committee for Quality Assurance (NCQA) standards and satisfy the requirements of the Special Rules For Network Plans of the Public Health Service Act. Issuers must ensure that the network of providers for standard plan offerings is comparable to the network of providers available for a similar product offered outside the Exchange. The network must also include a sufficient number of Essential Community Providers and providers that specialize in mental health and substance abuse services.
Issuers will be required to report quality information to Access Health CT, as well as results from the enrollee satisfaction survey system developed by HHS. Access Health CT will use the information to develop and maintain a quality rating system that will relate quality of care to price, per metal-level tier.
Risk Adjustment, Reinsurance, and Risk Corridors: Connecticut intends to administer its risk adjustment and reinsurance programs. In June 2012 Governor Malloy signed Public Act 12-166 into law establishing the requirement for an all-payer claims database (APCD), which will provide data to state agencies, including the Exchange, for purposes of reviewing health care utilization, cost, and quality data. Such a database will provide the baseline information to create a risk adjustment program, as well as to provide outcome quality data and enable analyses of Exchange policy initiatives. The Office of Health Reform and Innovation is developing the APCD program and established an APCD Advisory Group to guide the implementation process. Access Health CT received $6.5 million in Establishment Grant funding for the APCD program in August 2012. The APCD Advisory Group expects to release a Request for Proposals (RFP) for a data manager in June 2013.
Dental and Vision Benefits: In order to offer a stand-alone dental plan through the Exchange, issuers must provide three plan design options: high (85% Actuarial Value), low (75% Actuarial Value), and wellness (limited set of preventive and diagnostic services). Access Health CT requires all carriers submitting a QHP to separately price their pediatric dental essential health benefit.
Consumer Assistance and Outreach: The Brokers, Agents and Navigator Advisory Committee began meeting in April 2012 and in November 2012 the Access Health CT Board approved a program design that established two distinct outreach programs. The Navigator program will be an ongoing program managed by the Office of the Healthcare Advocate, while the Assisters program will be operational only from October 2013 through December 2013. Navigators will be responsible for training and managing Assisters, conducting public education activities, and providing eligibility and enrollment assistance. Assisters will be individuals who currently work at community-based organizations, such as libraries, unions, and health departments and will be trained to provide enrollment assistance in those settings on a part-time basis. Access Health CT anticipates hiring 300 part-time Assisters and will provide $6,000 grants for each Assister. Access Health CT will contract with seven Navigator organizations and plans to award $500,000 or more in Navigator grant funding on an annual basis. Access Health CT released an RFP for Assisters in April 2013 and will release an RFP for Navigators in early May.
The Exchange hired subcontractors to work on branding and messaging development for various stakeholder populations; a consumer research report was released in July 2012. In October 2012 Access Health CT released an RFP to solicit a subcontractor to build and service the required call-center and selected a vendor in February 2013. The call center will be operational in September and will support over 100 languages.
In November 2012, Access Health CT hired a marketing vendor and developed a marketing and community outreach plan and timeline. The outreach campaign includes the use of media, direct mail, in-person events, social media, public relations, and brokers. From November 2012 through March 2013, Access Health CT hosted a series of “Healthy Chat” town hall style events in communities across the state, to allow the general public to ask questions of industry experts, including the CEO of Access Health CT, and engage in dialogue about the upcoming changes. In February 2013, Access Health CT unveiled their logo and launched their website, including a subsidy calculator.
Small Business Health Options Program (SHOP) Exchange: In 2012, the Access Health CT Board decided to establish separate risk pools for the small group and individual markets but to use a single administrative Exchange to operate both markets. The Board also decided Connecticut should limit the definition of small employers to groups of 50 or fewer employees until it is required to expand the definition to groups of 100 or fewer employees in 2016. Employers will be able to choose between employee choice, employer choice, and sole source coverage models for their employees. A SHOP Advisory Committee began meeting in April 2012 and Access Health CT released a SHOP Request for Proposals in December 2012. In April 2013, Access Health CT hired a subcontractor to develop and manage the front-end and administrative platform for the SHOP. Access Health CT plans to launch the SHOP on October 1, 2013, despite the decision by HHS to allow states to delay implementation until 2015.
Information Technology (IT): Connecticut plans to have a streamlined, integrated eligibility determination for Medicaid, the Children’s Health Insurance Program (CHIP), and the Exchange that refers individuals to the appropriate program, communicates health plan choices and benefits to applicants, and enrolls individuals in health plans. In March 2012, the state released a Request for Information for a subcontractor to evaluate numerous Exchange functions including: eligibility determination for publicly subsidized coverage, management of qualified health plans, calculation of federal exchange subsidies, and consumer decision support tools. In September 2012, the state successfully identified a subcontractor to develop and implement the Exchange’s extensive operating technology and web portal that will be used to determine eligibility and enroll individuals, families, and small businesses in coverage.
Connecticut is also part of a consortium of states participating in the “Enroll UX 2014” project, which is a public-private partnership creating design standards for exchanges that all states can use.
Financing: Public Act 11-53 authorizes the Exchange to charge health carriers capable of offering a qualified health plan through the Exchange an assessment or user fee. In March 2013, the Board approved a policy through which the state will impose a market assessment to acquire funding for Access Health CT. The market assessment will apply to the entire small group and non-group market. Based on budget and enrollment estimates, a market assessment of around .67% of premiums will be required to fund the operations of the Exchange. Access Health CT will rely on Medicaid cost recovery, advertising, and other opportunities as further sources of revenue. Estimated annual operating costs for Access Health CT range from $25 to $35 million.
Basic Health Program (BHP): Connecticut is considering establishing an optional bridge program available through the Affordable Care Act (ACA) which allows states to use federal funding to offer subsidized health insurance to adults with incomes between 139 and 200% of the federal poverty level (FPL) who would otherwise be eligible to purchase subsidized coverage through an Exchange. The Office of Health Reform and Innovation established Work Groups including one on the Basic Health Plan which began meeting in April 2012 to develop recommendations. Legislation establishing a Basic Health Program was introduced but tabled for the 2012 legislative session (HB 5450). Due to the lack of federal guidance, it has been difficult for the state to move forward with planning a BHP.
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 the Exchange, cover certain defined health benefits. States must decide whether to benchmark their EHB plan to one of ten plans operating in the state or default to the largest small-group plan in the state. The Exchange Board recommended the state use ConnectiCare’s HMO plan as the benchmark plan, the Children’s Health Insurance Program (CHIP) as the pediatric dental supplement, and the Federal Employee Vision Plan (FEDVIP) as the pediatric vision supplement.
The Connecticut State Office of Policy and Management received a federal Exchange Planning grant of $1 million in September 2010 and a federal Level One Establishment grant of $6.7 million in August 2011 to work on IT systems and develop appropriate capacity for consumer assistance and reporting requirements. The Exchange was awarded a Level Two Establishment grant in August 2012 for $107.3 million to fund Exchange development through December 2014. In February 2013, the state was awarded a second Level One Establishment grant for $2.1 million to fund the implementation of an In-Person Assisters program.
In addition, Connecticut is a member of the consortium of New England states that received a federal Early Innovator Grant of $44 million to develop, share, and leverage insurance exchange technology. The multi-state consortium also includes Rhode Island, Maine, Vermont, and Massachusetts with the University of Massachusetts Medical School as the grant holder.[innovator]
On December 7, 2012, Connecticut 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 and complying with future guidance and regulations.
Additional information about Connecticut’s Health Insurance Exchange can be found here.