Exchange Implementation Advisory Committee September 20, :00pm-5:00pm UMBC Tech Center 1450 S. Rolling Road Baltimore, MD 21227

Transcription

1 Exchange Implementation Advisory Committee September 20, :00pm-5:00pm UMBC Tech Center 1450 S. Rolling Road Baltimore, MD Members Present Kevin Yang (Co-Chair) Tequila Terry (Co-Chair) Ken Hunter Lesley Wallace (by phone) Kathy Simmons Mary Lou Fox Lee Diemer Douglas Templeton Members Absent Louisa Tavakoli Vincent Ancona Paul Kniskern Heather Grzych Linda Dietsch Stephanie Scharpf John Fleig Jeffrey Warner Julia Huggins Sandy Walters Peter Beilenson Kevin Gavin Welcome and Introductions Tequila Terry, Director of Plan and Partner Management with the Exchange, welcomed the Exchange Implementation Advisory Committee (EIAC) members and attendees. Committee members introduced themselves to those assembled. Ms. Terry then introduced the Exchange s newly hired Director of Policy, Frank Kolb. Provider Information Management Scott Afzal, State Health Information Exchange Program Director with Chesapeake Regional Information System for Our Patients (CRISP), gave an overview of CRISP s work and explained how it will be applied by the Exchange. He began by describing the mission, vision, and governance structure of CRISP. He gave some background information to the committee about the national Health Information Exchange

2 (HIE) strategy and the concept of meaningful use, specifically noting some challenges his organization faces in establishing HIE interoperability in the region. Mr. Afzal then shared some details of CRISP s infrastructure design, as well as a description of the Master Patient Indexing process using the IBM Initiate system. In answer to a question from the committee, he explained that CRISP assigns a score to each item of demographic data. Those scores are compared to a scale established by CRISP. If the score is above a certain threshold, CRISP s systems designate the data as a match. If the score is below another threshold, the systems do not make a match. If the score falls between the two thresholds, CRISP staffers do a manual intervention to determine whether the data is a match. Next, Mr. Afzal provided numbers showing the progress CRISP has made in connecting providers to the system, as well as how often the system is queried for patient data. He listed CRISP s current focus areas, one of which is support for the Exchange. He then provided details about the portal that providers can use to access patient data, called the CRISP Query Portal, as well as plans currently underway to improve workflow on the portal. Mr. Afzal described a few other services available from CRISP, including CRISP Direct Secure Messaging, Encounter Notification Service, and Encounter Reporting Service. To conclude his overview of CRISP, he explained how the organization is funded and how it plans to sustain itself in the future. Next, Mr. Afzal addressed how CRISP will support the Exchange, describing three services it will provide: provider information management (PIM), master patient indexing services for the all payer claims database, and clinical summary care coordination service. Turning to the provider information management service in particular, Mr. Afzal laid out three functions CRISP will provide for the Exchange: Receive and process inbound provider and product/plan affiliation data from qualified health plans (QHPs) and Medicaid managed care organizations (MCOs) Verify and match provider demographic information against existing PIM data sources Make provider and product/plan data available via application programming interfaces (APIs) to the Exchange He noted that the PIM platform would support additional services beyond those the Exchange requires. At this point, committee members had a few questions for Mr. Afzal. One member asked whether the provider data definition standards would be those laid out by CRISP or those in use by carriers. Mr. Afzal explained that CRISP, the Exchange, and the carriers would have to work together to develop a common standard that is agreeable to all parties, including not only the provider file specification itself, but also procedures for addressing variations in the data. Several committee members described circumstances that are likely to complicate the development of the specification and procedures. Ms. Terry and Mr. Afzal assured the committee that the Exchange and CRISP are keeping those issues in mind as this relationship develops. Mr. Afzal then gave an overview of how the PIM will be generated, as well as how it will be structured for ongoing daily use. He explained that CRISP has a current relationship with a vendor, Optum, that

3 maintains a PIM Provider Directory, and that CRISP will make a copy of that directory (the Maryland PIM Instance) for the use of the Exchange. Carriers would load plan and product affiliations into the Maryland PIM Instance, and the Exchange would access that information through APIs for presentment on its consumer portal (the HIX). Next, Mr. Afzal described the Optum P360 database, out of which the Maryland PIM Instance will be developed, including how complete the provider records are currently. One committee member expressed confidence that CRISP, the Exchange, and the carriers will be able to work out any issues around provider addresses and similar contact information, given that carriers have a great deal of experience with those issues, but felt less confident about such data as practice type and specialty. Mr. Afzal then showed the committee how the existing Optum P360 database is developed and maintained, including how the data is cleaned on an ongoing basis. One issue still under discussion between CRISP and the Exchange is whether or not any provider information that is updated in the Maryland PIM Instance will be re-populated in the nationwide database. One member asked whether updated data in the Maryland PIM Instance will be shared with carriers in order to help improve their internal systems. Mr. Afzal replied that, while that would be technically possible, such a service is not contemplated in the current scope of the system. Finally, Mr. Afzal discussed the scope of work that each stakeholder in the process (CRISP, the Exchange, carriers, and MCOs) must tackle in order to make the system operational. In the ensuing discussion, the following points were raised: No decision has yet been made on how to leverage MCO provider data, but it is under discussion The Exchange s Level 2 Establishment Grant contains funding for establishing this system, but ongoing funding will have to be worked out in the broader sustainability plan Carriers are concerned about how much this will cost them, and would like to be able to use the provider data in their own operations CRISP would like to employ an existing standard for provider directories The Exchange will schedule Joint Application Design sessions to further develop the provider information management plan SHOP Questions List Kevin Yang, Chief Information Officer of the Exchange, began a discussion of the Small Business Health Options Program (SHOP) Questions List. He began by noting that the Exchange sent to each committee member a copy of the updated document, and asked for written feedback as soon as possible. Mr. Yang explained that the Exchange will present SHOP s larger issues to the Exchange Board at its October 9 meeting. One issue in particular that the Board will be asked to consider is about rating for SHOP groups. He said that the Exchange and the Maryland Insurance Administration (MIA) have met to discuss the delineation of duties between the two agencies, and that he would share that information with the committee.

4 Mr. Yang pointed out that the Board will be asked to weigh in, for the most part, on policy issues rather than on operational issues. He asked committee members to provide the Exchange with a list of any operational issues they feel are missing from the document. Group Rating in the Employee Choice Model Mr. Yang then reminded the committee about the issues around rate presentment for small employers when choosing the employee choice model. The Exchange is working through whether to present rates based on individual ages of the group members, or rates based on the average age of the entire small group. He noted that there are both positive and negative consequences of choosing one rate presentation policy over the other. If the Exchange presents rates based on the individual ages of group members, older members would lose the traditional benefit of community rating whereby their rates are kept lower due to the risk of the group being spread among younger members. On the other hand, if the Exchange presents rates based on the average age of the group, it would likely provide incentive for younger members to seek coverage on the individual market which, in turn, would lead to carriers having rated incorrectly to offset their risk. The points raised in the ensuing discussion included: A third rate presentment option may be feasible. An adjusted average age rate would consist of an initial rate based on average age of the entire group, and would be followed by another rate that would apply once the group members have selected plans. This option would help carriers rate correctly, but it would still likely introduce incentive for younger employers to seek coverage on the individual market. Additionally, it introduces a bait and switch issue, wherein an employer is presented one rate when setting up the group, only to find a different rate charged when the contract takes effect. CalChoice, a program for small employers in California, uses an age-banded individual rate matrix. o CalChoice has 150,000 members, which was characterized by one member as not giant, but not tiny. o One member described the incentives for employers to use CalChoice as being the ease of administration combined with the benefits of employee choice. o Another member noted that the CalChoice model failed when it was tried in New Jersey. While individual rating will create a disincentive for employers to hire older workers, that happens in the market today, and thus does not introduce a new distortion. Committee members are divided on how likely small employers are to elect the employee choice model. Mr. Hunter will provide the committee a survey his organization conducted on that question. Contribution Amount Mr. Yang then brought up the topic of contribution amount. He noted that the MIA does not and will not regulate this activity. He asked the committee to comment on what options the Exchange should give employers in setting up their contribution amount, ranging from individual contribution amounts

5 for each employee, to contribution amounts tied to classes of employees, to a single mandated contribution amount for all employees. The committee brought up several points in the discussion: A uniform contribution defined in terms of percentage will likely avoid discrimination issues, whereas uniform dollar amounts could be discriminatory. It may be possible for the Exchange to offer employers a range of options with a caveat that if the employer chooses a discriminatory setup, tax credits may not be available. While the Exchange lacks the authority to restrict contribution rules, it would like to provide useful tools to employers to manage contribution. In today s market, there is no legally binding minimum contribution amount, but it is a best practice among carriers to require at least 50% employer contribution. The Exchange will ask the Center for Consumer Information and Insurance Oversight (CCIIO) to provide advice on this issue, as well as on the status of nondiscrimination testing. Carrier-Employer Contracting in the Employee Choice Model Finally, Mr. Yang asked the committee to revisit the issue of contracting between carriers and employers in the employee choice model, and how that affects rates. Even though some carriers may not gain enrollees from a group at the beginning of its plan year, newly eligible employees may join mid-year. The committee felt that any mid-year plans must be offered at the rate based on the plan start date of the group. The committee also felt it was unnecessary for carriers to build the group in their systems before they have any enrollees. Building on that point, there would be no contractual relationship between the employer and the carrier until there is an enrolled member from that group. The rules stating that the mid-year employee will be presented with the rates as of the group s anniversary date would be codified in the contract between the carrier and the Exchange. Public Comments There were no public comments.