Patient Protection and Affordable Care Act; Increasing Consumer Choice Through the Sale of Individual Health Insurance Coverage Across State Lines Through Health Care Choice Compacts, 8657-8660 [2019-04270]
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Federal Register / Vol. 84, No. 47 / Monday, March 11, 2019 / Proposed Rules
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[FR Doc. 2019–04383 Filed 3–8–19; 8:45 am]
BILLING CODE 6560–50–P
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Centers for Medicare & Medicaid
Services
42 CFR Chapter IV
Office of the Secretary
45 CFR Subtitle A
[CMS–9921–NC]
RIN 0938–ZB45
Patient Protection and Affordable Care
Act; Increasing Consumer Choice
Through the Sale of Individual Health
Insurance Coverage Across State
Lines Through Health Care Choice
Compacts
Centers for Medicare &
Medicaid Services (CMS), HHS.
ACTION: Request for information.
AGENCY:
This request for information
(RFI) solicits comment from interested
parties on how to eliminate barriers to
and enhance health insurance issuers’
ability to sell individual health
insurance coverage across state lines,
primarily pursuant to Health Care
Choice Compacts. This RFI was written
in connection with Executive Order
13813, ‘‘Promoting Healthcare Choice
and Competition Across the United
States,’’ which directs the
Administration, including the
Department of Health and Human
Services (HHS), to the extent consistent
with law, to facilitate the purchase of
health insurance coverage across state
lines. HHS is committed to increasing
health insurance coverage options under
Title I of the Patient Protection and
Affordable Care Act.
DATES: Comment Date: To be assured
consideration, comments must be
received at one of the addresses
SUMMARY:
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8657
provided below, no later than 5 p.m. on
May 6, 2019.
ADDRESSES: In commenting, please refer
to file code CMS–9921–NC. Because of
staff and resource limitations, we cannot
accept comments by facsimile (FAX)
transmission.
Comments, including mass comment
submissions, must be submitted in one
of the following three ways (please
choose only one of the ways listed):
1. Electronically. You may submit
electronic comments on this regulation
to https://www.regulations.gov. Follow
the ‘‘Submit a comment’’ instructions.
2. By regular mail. You may mail
written comments to the following
address ONLY: Centers for Medicare &
Medicaid Services, Department of
Health and Human Services, Attention:
CMS–9921–NC, P.O. Box 8016,
Baltimore, MD 21244–8016.
Please allow sufficient time for mailed
comments to be received before the
close of the comment period.
3. By express or overnight mail. You
may send written comments to the
following address ONLY: Centers for
Medicare & Medicaid Services,
Department of Health and Human
Services, Attention: CMS–9921–NC,
Mail Stop C4–26–05, 7500 Security
Boulevard, Baltimore, MD 21244–1850.
For information on viewing public
comments, see the beginning of the
SUPPLEMENTARY INFORMATION section.
FOR FURTHER INFORMATION CONTACT: Cam
Moultrie Clemmons, (206) 615–2338.
SUPPLEMENTARY INFORMATION:
Submission of Comments: All
submissions received must include the
Agency file code CMS–9921–NC for this
notice.
Inspection of Public Comments: All
comments received before the close of
the comment period are available for
viewing by the public, including any
personally identifiable or confidential
business information that is included in
a comment. We post all comments
received before the close of the
comment period on the following
website as soon as possible after they
have been received: https://
www.regulations.gov. Follow the search
instructions on that website to view
public comments.
I. Background
On October 12, 2017, President
Trump issued Executive Order 13813,
‘‘Promoting Healthcare Choice and
Competition Across the United States,’’
which states the policy of the
Administration will be ‘‘to the extent
consistent with law, to facilitate the
purchase of insurance across State lines
and the development and operation of a
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Federal Register / Vol. 84, No. 47 / Monday, March 11, 2019 / Proposed Rules
healthcare system that provides highquality care at affordable prices for the
American people.’’ 1 The Executive
Order reflects the Administration’s
intention to put downward pressure on
premiums by providing more
meaningful choices for consumers and
increasing competition. The Department
of Health and Human Services (HHS)
intends to work with states to innovate
within the health insurance market by
considering additional mechanisms for
the purchase of individual health
insurance coverage that are less
burdened by regulatory requirements
and will therefore simplify operations
and lower costs for health insurance
issuers, with the ultimate goal of
lowering prices for coverage and
increasing options for United States
consumers.
Executive Order 13813 further directs
the Secretary of HHS, in consultation
with the Secretaries of the Treasury,
Labor, and the Federal Trade
Commission, within 180 days from the
date of the Executive Order, and every
2 years thereafter, to provide a report to
the President that details the extent to
which existing state and federal laws,
regulations, guidance, requirements,
and policies fail to conform to the
policies set forth in section 1 of the
Executive Order, including the
facilitation of the purchase of insurance
across state lines, and identifies actions
that states or the federal government
could take in furtherance of the policies
set forth in section 1 of the Executive
Order. Comments provided in response
to this Request for Information (RFI)
may help to inform future reports.
While there is no federal law that
generally prohibits the sale of health
insurance coverage across state lines,
the McCarran-Ferguson Act of 1945 2
establishes states as the primary
regulators of insurance and declares that
a federal law cannot preempt any state
law that regulates the business of
insurance, or that imposes a fee or tax
upon such business, unless such federal
law specifically relates to the business
of insurance. While several mechanisms
to facilitate the sale of individual health
insurance coverage across state lines
exist, such as Interstate Health
Compacts enacted through state
legislation and the allowance of the sale
of insurance from out-of-state insurers
by a state, this RFI primarily explores
options related to Health Care Choice
Compacts related to section 1333 of the
Patient Protection and Affordable Care
1 https://www.whitehouse.gov/the-press-office/
2017/10/12/presidential-executive-order-promotinghealthcare-choice-and-competition.
2 15 U.S.C. 1011–1015.
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Act (PPACA) (Pub. L. 111–148) since
section 1333 provides a specific role for
the federal government.
Section 1333 of the PPACA provides
for the establishment of a regulatory
framework 3 that allows two or more
states to enter into a Health Care Choice
Compact. For plan years beginning on or
after January 1, 2016, under a Health
Care Choice Compact, a health
insurance issuer could offer one or more
qualified health plans (QHPs) 4 in the
individual health insurance market in
any state included in the compact. The
QHP generally would only be subject to
the laws and regulations of the state in
which the health insurance coverage
was written or issued.5 Section 1333 of
the PPACA does not address the sale of
group health insurance coverage across
state lines or the sale of individual
market policies that are not QHPs. In
order to enter into a Health Care Choice
Compact, a state must pass legislation,
after March 23, 2010, specifically
authorizing it to do so. To date, no states
have passed legislation authorizing the
state to enter into a Health Care Choice
Compact as contemplated by section
3 Section 1333 of the PPACA requires that no later
than July 1, 2013, the Secretary of HHS, in
consultation with the National Association of
Insurance Commissioners, issue regulations for the
creation of Health Care Choice Compacts. To date,
HHS has not promulgated rules implementing
section 1333 of the PPACA.
4 Qualified health plan, or QHP, means a health
plan that has in effect a certification that it meets
the standards described in subpart C of part 156
issued or recognized by each Exchange through
which such plan is offered in accordance with the
process described in subpart K of part 155. See 45
CFR 155.20.
5 Additionally, the issuer would be subject to the
market conduct, unfair trade practices, network
adequacy, and consumer protection standards
(including standards relating to rating), including
addressing disputes as to the performance of the
contract, of the state in which the policyholder
resides. The health insurance issuer must be
licensed in or submit to the jurisdiction and be
subject to the aforementioned standards of each
state in which it offers health insurance coverage
under the compact. In addition, the health
insurance issuer must notify the policyholder that
the coverage may not otherwise be subject to the
laws of the state in which the policyholder resides.
Under section 1333 of the PPACA, HHS has the
authority to approve Health Care Choice Compacts
if it determines that they would provide coverage
that would be at least as comprehensive as health
insurance coverage sold through the Exchanges that
offer essential health benefits, provide coverage and
cost-sharing protections against excessive out-ofpocket spending at least as affordable as coverage
under Title I of the PPACA, provide coverage to at
least a comparable number of residents as coverage
under Title I of the PPACA, not increase the federal
deficit, and not weaken the enforcement of the laws
and regulations of any state that is included in the
compact that would still apply to the issuer in
states in which the purchaser of coverage resides
that is not the state in which the coverage was
issued or written under the Health Care Choice
Compact requirements. To date, HHS has not
received any requests for approval of a Health Care
Choice Compact.
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1333 of the PPACA or created a Health
Care Choice Compact, and no issuer has
offered health insurance coverage
through a Health Care Choice Compact.
However, four states (Georgia, Maine,
Oklahoma, and Wyoming) have passed
laws authorizing the sale of health
insurance coverage across state lines.
Under Georgia law,6 insurers are
authorized to offer individual accident
and sickness insurance policies in
Georgia that have been approved for
issuance in other states, provided
specified minimum criteria are met.
Under Maine law,7 domestic insurers or
licensed health maintenance
organizations that are authorized to
transact individual health insurance in
Maine are permitted to offer for sale in
Maine an individual health insurance
policy duly authorized for sale in
Connecticut, Massachusetts, New
Hampshire, Rhode Island, or Vermont
by a parent or corporate affiliate,
provided specified minimum criteria are
met. Oklahoma law 8 allows issuers
authorized to engage in the business of
insurance in a state which has a
legislatively approved compact with
Oklahoma, and not so authorized in
Oklahoma, to issue individual accident
and health insurance policies in
Oklahoma, provided specified
minimum criteria are met. Wyoming
law 9 allows insurers authorized to
engage in the business of insurance in
a state identified by the Commissioner
as having insurance laws sufficiently
consistent with Wyoming laws, and so
authorized in Wyoming, to issue in
Wyoming selected comprehensive
individual medical and surgical
insurance policies that have been
approved in other such states, provided
specified minimum criteria are met.
Three other states have passed laws to
study the feasibility of selling insurance
across state lines.10 Since 2010, bills
that would permit the purchase of
health insurance coverage across state
lines have been filed but not passed in
an additional 11 states.11
Separately, ‘‘Interstate Health
Compacts,’’ also known as ‘‘Freedom
6 Ga.
Code Ann., sec. 33–29A–30, et seq.
Rev. Stat. tit. 24–A, sec. 405–B.
8 Okla. Stat. Ann. tit. 36, sec. 4414.
9 Wyo. Stat. Ann. sec. 26–18–201, et seq.
10 Kentucky (2012 Ken. H.B. 265. Sec. 10), Rhode
Island (RI General Law 27–67), and Washington
(Chapter 303, Laws of the State of Washington 2008,
section 8, (SSB 5261)).
11 Arizona (SB 1593 of 2011), Indiana (HB 1063
of 2011 and HB 1013 of 2013), Minnesota (H 1859
and S 349 of 2015), Montana (H 280 of 2013), New
Hampshire (H 327 and S 150 of 2011), New Jersey
(A 1558, A 4364, and S 2806 of 2017), Pennsylvania
(HB 47 of 2011–12 and SB 346 of 2013–14), South
Carolina (S 185 of 2011 and S 886 of 2014), Texas
(HCR 90 of 2017), Washington (S 5540 of 2013–14),
and West Virginia (HB 2801 and SB 419 of 2011).
7 Me.
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Health Compacts,’’ are another type of
compact, advocated by Competitive
Governance Action and the American
Legislative Exchange Council, which
could provide broader interstate health
markets than the Health Care Choice
Compacts under section 1333 of the
PPACA. Interstate Health Compacts
include a provision allowing for the
suspension of the operation of all
federal laws, rules, regulations, and
orders regarding health care that are
inconsistent with the laws and
regulations adopted by the member state
pursuant to the compact and aim to
secure federal funding that is not
conditional on any action of the member
states.12 The creation of any such
Interstate Health Compact requires
formal Congressional approval pursuant
to Article 1, Section 10, of the United
States Constitution. As of January 2017,
at least nine states 13 have enacted
Interstate Health Compacts; however, no
requests for Congressional approval of
the Interstate Health Compacts have
been submitted.
No health insurance issuers or
consumers appear to have access to the
increased flexibility that could be
afforded by state laws related to the sale
of health insurance coverage across state
lines.
II. Solicitation of Public Comments
HHS solicits public comments about
actions that could further facilitate
selling individual health insurance
coverage across state lines. Comments
are requested in response to the
questions below with respect to
individual health insurance coverage.
The Administration recognizes and
strongly supports the fundamental role
states play in regulating insurance.
Providing states with flexibility to
address the unique needs of their health
insurance markets is a key component
of achieving the goals stated in the
Executive Order. This RFI is not
intended to inform policy which will
preempt state law or otherwise impede
the role states play as the primary
regulators of insurance.
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12 See
e.g., Ala. Code sec. 22–21A; Ga. Code Ann.
sec. 31–48–1; Ind. Code sec. 12–16.5–1–1, et seq.;
Kan. Stat. Ann. 65–6230; Mo. Rev. Stat. sec.
191.025; Okla. St. Ann. tit. 63, sec. 7300; S.C. Code
Ann. sec. 44–10–10, et seq.; and Tex. Ins. Code
Ann. sec. 5002.001. The legality of suspending the
operation of federal law is not addressed herein, but
this type of provision likely will face legal
challenges.
13 Alabama, Georgia, Indiana, Kansas, Missouri,
Oklahoma, South Carolina, Texas, and Utah
(expired July 2014).
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A. Expanding Access to Health
Insurance Coverage Across State Lines
1. What are the practical advantages
and disadvantages of allowing health
insurance issuers to sell individual
health insurance coverage across state
lines through Health Care Choice
Compacts?
2. What actions could the federal
government undertake to facilitate the
state implementation of the sale of
individual health insurance coverage
across state lines pursuant to section
1333 of the PPACA?
3. While four states have passed laws
specifically authorizing the sale of
individual health insurance across state
lines, we understand that no action to
implement these laws has been taken.
Additionally, nine states have enacted
laws authorizing the creation of
Interstate Health Compacts, yet we
understand that no such Compact has
been created. Why have states not taken
advantage of these opportunities? Are
there federal or state statutory and/or
regulatory barriers that prevent states
from doing so?
4. Should HHS promote the sale of
QHPs through Health Care Choice
Compacts across state lines and why?
5. How would the sale of individual
health insurance coverage across state
lines through Health Care Choice
Compacts impact access to QHPs? We
are particularly interested in the impact
on counties that do not have many
options for QHP coverage in their
current markets and whether the sale of
health insurance coverage across state
lines would increase or decrease the
number of issuers offering QHPs in
these counties.
6. Are there mechanisms, such as
memoranda of understanding or other
contractual arrangements, other than
Health Care Choice Compacts
established pursuant to section 1333 of
the PPACA, that states could utilize to
facilitate the sale of individual health
insurance coverage across state lines?
Would selling health insurance coverage
such as short-term, limited-duration
insurance; state-regulated farm bureau
coverage; or insurance licensed by a
state as defined under section
2791(d)(14) of the Public Health Service
Act (PHS Act) (to include each of the
several states, the District of Columbia,
Puerto Rico, the Virgin Islands, Guam,
American Samoa, and the Northern
Mariana Islands) 14 to individuals
14 On July 14, 2016, the CMS Administrator sent
letters to the territories stating the new market
reforms in the PHS Act enacted in title I of the
PPACA are governed by the definition of ‘‘state’’ set
forth in that title, and therefore do not apply to
issuers of health insurance coverage in the
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pursuant to such state agreements help
facilitate the sale of individual health
insurance coverage across state lines?
Consider whether the type of coverage
is relevant to, or would impact, the form
or nature of the agreements utilized by
states.
B. Operationalizing the Sale of Health
Insurance Coverage Across State Lines
1. Is the structure of Health Care
Choice Compacts contemplated by
section 1333 of the PPACA effective in
facilitating the sale of individual health
insurance coverage across state lines?
To date, no states have passed laws
specifically authorizing the state to
enter into a Health Care Choice Compact
under section 1333 of the PPACA. Why
have states not enacted such laws? Are
there any necessary revisions to section
to 1333 of the PPACA that would
facilitate the sale of health insurance
coverage across state lines?
2. How difficult is it for small and/or
regional health insurance issuers to
develop provider networks in multiple
states that could be used for health
insurance coverage sold pursuant to
Health Care Choice Compacts, and what
are the causes of any such difficulties?
For individual market health insurance
issuers that already have a national
provider network, what are the
challenges for selling individual health
insurance coverage across state lines
through Health Care Choice Compacts?
In what ways could the federal
government facilitate expanding and
strengthening provider networks?
3. How would states allowing health
insurance issuers to sell individual
health insurance coverage across state
lines through Health Care Choice
Compacts (if the health insurance
coverage only covers health benefits in
accordance with federal law and the
laws of the state where the coverage is
written) impact access to and the
utilization of medical services?
4. What new and existing consumer
protections are needed to protect
policyholders that reside in one state
but purchase individual health
insurance coverage from a health
insurance issuer in another state
territories. The letter states the definition of ‘‘state’’
set forth in the PHS Act will apply only to PHS Act
requirements in place prior to the enactment of the
PPACA, or subsequently enacted in legislation that
does not include a separate definition of ‘‘state’’ (as
the PPACA does). This analysis applies only to
health insurance that is governed by the PHS Act.
The PHS Act, the Employee Retirement Income
Security Act (ERISA), and the Internal Revenue
Code (Code) requirements applicable to group
health plans continue to apply to such coverage.
The letters are available at https://www.cms.gov/
CCIIO/Resources/Letters/#HealthMarket
Reforms.
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Federal Register / Vol. 84, No. 47 / Monday, March 11, 2019 / Proposed Rules
pursuant to a Health Care Choice
Compact? How would allowing health
insurance issuers to sell individual
health insurance coverage across state
lines impact the ability of state
regulators to assist consumers or impact
the ability of state courts to resolve legal
disputes when the policyholder resides
in a state other than that in which the
policy was written, pursuant to a Health
Care Choice Compact?
5. To what extent, if any, would the
sale of individual health insurance
coverage across state lines pursuant to a
Health Care Choice Compact positively
or negatively impact the following
populations: Persons with pre-existing
conditions; persons with disabilities;
persons with chronic physical health
conditions; expectant mothers;
newborns; American Indians and Alaska
Natives and tribal entities; veterans; and
persons with behavioral health
conditions, including both mental
health and substance use disorder
conditions?
6. In general, which statutes or
regulations of the issuing state should
apply to an individual market policy
sold in another state pursuant to a
Health Care Choice Compact, and which
statutes or regulations, if any, of the
state in which the policy is sold should
apply? To what extent should policies
being sold in another state pursuant to
a Health Care Choice Compact be
required to cover the state-required
benefits of that state, and to what extent
should such policies be required to
cover the state-required benefits of the
issuing state?
C. Financial Impact of Selling Health
Insurance Coverage Across State Lines
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1. What policies, including how
premiums and rates are established and
reviewed, and how risk is pooled,
should be in place with respect to rating
and pricing of health insurance coverage
sold across state lines pursuant to
Health Care Choice Compacts?
2. What impact would the sale of
health insurance coverage across state
lines pursuant to Health Care Choice
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Compacts have on health insurance
coverage premiums for purchasers of
insurance across state lines and for
policyholders purchasing in-state
insurance in the state where the acrossstate-lines purchasers live or in the state
in which the issuer is located? Would
the impact be different for policyholders
in different states?
3. What impact would the sale of
health insurance coverage across state
lines pursuant to Health Care Choice
Compacts have on policyholders’ out-ofpocket expenses? Would the impact be
different for different policyholders?
4. What impact would the sale of
health insurance coverage across state
lines pursuant to Health Care Choice
Compact have on a health insurance
issuer’s operating costs?
5. What impact would the sale of
health insurance coverage across state
lines pursuant to Health Care Choice
Compacts have on market participation
in each state?
6. What impact would the sale of
health insurance coverage across state
lines pursuant to Health Care Choice
Compacts have on competition and the
viability of health insurance issuers that
elect not to sell health insurance
coverage across state lines?
7. What impact would the sale of
health insurance coverage across state
lines pursuant to Health Care Choice
Compacts have on health care cost
growth and medical inflation?
8. What impact would the sale of
health insurance coverage across state
lines pursuant to Health Care Choice
Compacts have on consolidation of
health insurance issuers?
9. What impact would the sale of
health insurance coverage across state
lines pursuant to Health Care Choice
Compacts have on the market risk pools
of the states where the health insurance
issuer is domiciled and where the
policyholder resides?
10. What impact would the sale of
health insurance coverage across state
lines pursuant to Health Care Choice
Compacts have on the size and
composition of the uninsured
population?
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III. Collection of Information
Requirements
This document does not impose
information collection requirements,
that is, reporting, recordkeeping or
third-party disclosure requirements.
This RFI constitutes a general
solicitation of comments. In accordance
with the implementing regulations of
the Paperwork Reduction Act (PRA) at
5 CFR 1320.3(h)(4), information subject
to the PRA does not generally include
‘‘facts or opinions submitted in response
to general solicitations of comments
from the public, published in the
Federal Register or other publications,
regardless of the form or format thereof,
provided that no person is required to
supply specific information pertaining
to the commenter, other than that
necessary for self-identification, as a
condition of the agency’s full
consideration of the comment.’’
Consequently, there is no need for
review by the Office of Management and
Budget under the authority of the
Paperwork Reduction Act of 1995 (44
U.S.C. 3501, et seq.).
IV. Response to Comments
Because of the large number of public
comments we normally receive on
Federal Register documents, we are not
able to acknowledge or respond to them
individually. We will consider all
comments we receive by the date and
time specified in the DATES section of
this preamble, and, in the event we
issue a subsequent document, we will
respond to the comments in the
preamble to that document.
Dated: January 28, 2019.
Seema Verma,
Administrator, Centers for Medicare &
Medicaid Services.
Dated: February 14, 2019.
Alex M. Azar II,
Secretary, Department of Health and Human
Services.
[FR Doc. 2019–04270 Filed 3–6–19; 4:15 pm]
BILLING CODE 4120–01–P
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Agencies
[Federal Register Volume 84, Number 47 (Monday, March 11, 2019)]
[Proposed Rules]
[Pages 8657-8660]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-04270]
=======================================================================
-----------------------------------------------------------------------
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Centers for Medicare & Medicaid Services
42 CFR Chapter IV
Office of the Secretary
45 CFR Subtitle A
[CMS-9921-NC]
RIN 0938-ZB45
Patient Protection and Affordable Care Act; Increasing Consumer
Choice Through the Sale of Individual Health Insurance Coverage Across
State Lines Through Health Care Choice Compacts
AGENCY: Centers for Medicare & Medicaid Services (CMS), HHS.
ACTION: Request for information.
-----------------------------------------------------------------------
SUMMARY: This request for information (RFI) solicits comment from
interested parties on how to eliminate barriers to and enhance health
insurance issuers' ability to sell individual health insurance coverage
across state lines, primarily pursuant to Health Care Choice Compacts.
This RFI was written in connection with Executive Order 13813,
``Promoting Healthcare Choice and Competition Across the United
States,'' which directs the Administration, including the Department of
Health and Human Services (HHS), to the extent consistent with law, to
facilitate the purchase of health insurance coverage across state
lines. HHS is committed to increasing health insurance coverage options
under Title I of the Patient Protection and Affordable Care Act.
DATES: Comment Date: To be assured consideration, comments must be
received at one of the addresses provided below, no later than 5 p.m.
on May 6, 2019.
ADDRESSES: In commenting, please refer to file code CMS-9921-NC.
Because of staff and resource limitations, we cannot accept comments by
facsimile (FAX) transmission.
Comments, including mass comment submissions, must be submitted in
one of the following three ways (please choose only one of the ways
listed):
1. Electronically. You may submit electronic comments on this
regulation to https://www.regulations.gov. Follow the ``Submit a
comment'' instructions.
2. By regular mail. You may mail written comments to the following
address ONLY: Centers for Medicare & Medicaid Services, Department of
Health and Human Services, Attention: CMS-9921-NC, P.O. Box 8016,
Baltimore, MD 21244-8016.
Please allow sufficient time for mailed comments to be received
before the close of the comment period.
3. By express or overnight mail. You may send written comments to
the following address ONLY: Centers for Medicare & Medicaid Services,
Department of Health and Human Services, Attention: CMS-9921-NC, Mail
Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850.
For information on viewing public comments, see the beginning of
the SUPPLEMENTARY INFORMATION section.
FOR FURTHER INFORMATION CONTACT: Cam Moultrie Clemmons, (206) 615-2338.
SUPPLEMENTARY INFORMATION:
Submission of Comments: All submissions received must include the
Agency file code CMS-9921-NC for this notice.
Inspection of Public Comments: All comments received before the
close of the comment period are available for viewing by the public,
including any personally identifiable or confidential business
information that is included in a comment. We post all comments
received before the close of the comment period on the following
website as soon as possible after they have been received: https://www.regulations.gov. Follow the search instructions on that website to
view public comments.
I. Background
On October 12, 2017, President Trump issued Executive Order 13813,
``Promoting Healthcare Choice and Competition Across the United
States,'' which states the policy of the Administration will be ``to
the extent consistent with law, to facilitate the purchase of insurance
across State lines and the development and operation of a
[[Page 8658]]
healthcare system that provides high-quality care at affordable prices
for the American people.'' \1\ The Executive Order reflects the
Administration's intention to put downward pressure on premiums by
providing more meaningful choices for consumers and increasing
competition. The Department of Health and Human Services (HHS) intends
to work with states to innovate within the health insurance market by
considering additional mechanisms for the purchase of individual health
insurance coverage that are less burdened by regulatory requirements
and will therefore simplify operations and lower costs for health
insurance issuers, with the ultimate goal of lowering prices for
coverage and increasing options for United States consumers.
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\1\ https://www.whitehouse.gov/the-press-office/2017/10/12/presidential-executive-order-promoting-healthcare-choice-and-competition.
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Executive Order 13813 further directs the Secretary of HHS, in
consultation with the Secretaries of the Treasury, Labor, and the
Federal Trade Commission, within 180 days from the date of the
Executive Order, and every 2 years thereafter, to provide a report to
the President that details the extent to which existing state and
federal laws, regulations, guidance, requirements, and policies fail to
conform to the policies set forth in section 1 of the Executive Order,
including the facilitation of the purchase of insurance across state
lines, and identifies actions that states or the federal government
could take in furtherance of the policies set forth in section 1 of the
Executive Order. Comments provided in response to this Request for
Information (RFI) may help to inform future reports.
While there is no federal law that generally prohibits the sale of
health insurance coverage across state lines, the McCarran-Ferguson Act
of 1945 \2\ establishes states as the primary regulators of insurance
and declares that a federal law cannot preempt any state law that
regulates the business of insurance, or that imposes a fee or tax upon
such business, unless such federal law specifically relates to the
business of insurance. While several mechanisms to facilitate the sale
of individual health insurance coverage across state lines exist, such
as Interstate Health Compacts enacted through state legislation and the
allowance of the sale of insurance from out-of-state insurers by a
state, this RFI primarily explores options related to Health Care
Choice Compacts related to section 1333 of the Patient Protection and
Affordable Care Act (PPACA) (Pub. L. 111-148) since section 1333
provides a specific role for the federal government.
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\2\ 15 U.S.C. 1011-1015.
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Section 1333 of the PPACA provides for the establishment of a
regulatory framework \3\ that allows two or more states to enter into a
Health Care Choice Compact. For plan years beginning on or after
January 1, 2016, under a Health Care Choice Compact, a health insurance
issuer could offer one or more qualified health plans (QHPs) \4\ in the
individual health insurance market in any state included in the
compact. The QHP generally would only be subject to the laws and
regulations of the state in which the health insurance coverage was
written or issued.\5\ Section 1333 of the PPACA does not address the
sale of group health insurance coverage across state lines or the sale
of individual market policies that are not QHPs. In order to enter into
a Health Care Choice Compact, a state must pass legislation, after
March 23, 2010, specifically authorizing it to do so. To date, no
states have passed legislation authorizing the state to enter into a
Health Care Choice Compact as contemplated by section 1333 of the PPACA
or created a Health Care Choice Compact, and no issuer has offered
health insurance coverage through a Health Care Choice Compact.
However, four states (Georgia, Maine, Oklahoma, and Wyoming) have
passed laws authorizing the sale of health insurance coverage across
state lines. Under Georgia law,\6\ insurers are authorized to offer
individual accident and sickness insurance policies in Georgia that
have been approved for issuance in other states, provided specified
minimum criteria are met. Under Maine law,\7\ domestic insurers or
licensed health maintenance organizations that are authorized to
transact individual health insurance in Maine are permitted to offer
for sale in Maine an individual health insurance policy duly authorized
for sale in Connecticut, Massachusetts, New Hampshire, Rhode Island, or
Vermont by a parent or corporate affiliate, provided specified minimum
criteria are met. Oklahoma law \8\ allows issuers authorized to engage
in the business of insurance in a state which has a legislatively
approved compact with Oklahoma, and not so authorized in Oklahoma, to
issue individual accident and health insurance policies in Oklahoma,
provided specified minimum criteria are met. Wyoming law \9\ allows
insurers authorized to engage in the business of insurance in a state
identified by the Commissioner as having insurance laws sufficiently
consistent with Wyoming laws, and so authorized in Wyoming, to issue in
Wyoming selected comprehensive individual medical and surgical
insurance policies that have been approved in other such states,
provided specified minimum criteria are met.
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\3\ Section 1333 of the PPACA requires that no later than July
1, 2013, the Secretary of HHS, in consultation with the National
Association of Insurance Commissioners, issue regulations for the
creation of Health Care Choice Compacts. To date, HHS has not
promulgated rules implementing section 1333 of the PPACA.
\4\ Qualified health plan, or QHP, means a health plan that has
in effect a certification that it meets the standards described in
subpart C of part 156 issued or recognized by each Exchange through
which such plan is offered in accordance with the process described
in subpart K of part 155. See 45 CFR 155.20.
\5\ Additionally, the issuer would be subject to the market
conduct, unfair trade practices, network adequacy, and consumer
protection standards (including standards relating to rating),
including addressing disputes as to the performance of the contract,
of the state in which the policyholder resides. The health insurance
issuer must be licensed in or submit to the jurisdiction and be
subject to the aforementioned standards of each state in which it
offers health insurance coverage under the compact. In addition, the
health insurance issuer must notify the policyholder that the
coverage may not otherwise be subject to the laws of the state in
which the policyholder resides. Under section 1333 of the PPACA, HHS
has the authority to approve Health Care Choice Compacts if it
determines that they would provide coverage that would be at least
as comprehensive as health insurance coverage sold through the
Exchanges that offer essential health benefits, provide coverage and
cost-sharing protections against excessive out-of-pocket spending at
least as affordable as coverage under Title I of the PPACA, provide
coverage to at least a comparable number of residents as coverage
under Title I of the PPACA, not increase the federal deficit, and
not weaken the enforcement of the laws and regulations of any state
that is included in the compact that would still apply to the issuer
in states in which the purchaser of coverage resides that is not the
state in which the coverage was issued or written under the Health
Care Choice Compact requirements. To date, HHS has not received any
requests for approval of a Health Care Choice Compact.
\6\ Ga. Code Ann., sec. 33-29A-30, et seq.
\7\ Me. Rev. Stat. tit. 24-A, sec. 405-B.
\8\ Okla. Stat. Ann. tit. 36, sec. 4414.
\9\ Wyo. Stat. Ann. sec. 26-18-201, et seq.
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Three other states have passed laws to study the feasibility of
selling insurance across state lines.\10\ Since 2010, bills that would
permit the purchase of health insurance coverage across state lines
have been filed but not passed in an additional 11 states.\11\
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\10\ Kentucky (2012 Ken. H.B. 265. Sec. 10), Rhode Island (RI
General Law 27-67), and Washington (Chapter 303, Laws of the State
of Washington 2008, section 8, (SSB 5261)).
\11\ Arizona (SB 1593 of 2011), Indiana (HB 1063 of 2011 and HB
1013 of 2013), Minnesota (H 1859 and S 349 of 2015), Montana (H 280
of 2013), New Hampshire (H 327 and S 150 of 2011), New Jersey (A
1558, A 4364, and S 2806 of 2017), Pennsylvania (HB 47 of 2011-12
and SB 346 of 2013-14), South Carolina (S 185 of 2011 and S 886 of
2014), Texas (HCR 90 of 2017), Washington (S 5540 of 2013-14), and
West Virginia (HB 2801 and SB 419 of 2011).
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Separately, ``Interstate Health Compacts,'' also known as ``Freedom
[[Page 8659]]
Health Compacts,'' are another type of compact, advocated by
Competitive Governance Action and the American Legislative Exchange
Council, which could provide broader interstate health markets than the
Health Care Choice Compacts under section 1333 of the PPACA. Interstate
Health Compacts include a provision allowing for the suspension of the
operation of all federal laws, rules, regulations, and orders regarding
health care that are inconsistent with the laws and regulations adopted
by the member state pursuant to the compact and aim to secure federal
funding that is not conditional on any action of the member states.\12\
The creation of any such Interstate Health Compact requires formal
Congressional approval pursuant to Article 1, Section 10, of the United
States Constitution. As of January 2017, at least nine states \13\ have
enacted Interstate Health Compacts; however, no requests for
Congressional approval of the Interstate Health Compacts have been
submitted.
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\12\ See e.g., Ala. Code sec. 22-21A; Ga. Code Ann. sec. 31-48-
1; Ind. Code sec. 12-16.5-1-1, et seq.; Kan. Stat. Ann. 65-6230; Mo.
Rev. Stat. sec. 191.025; Okla. St. Ann. tit. 63, sec. 7300; S.C.
Code Ann. sec. 44-10-10, et seq.; and Tex. Ins. Code Ann. sec.
5002.001. The legality of suspending the operation of federal law is
not addressed herein, but this type of provision likely will face
legal challenges.
\13\ Alabama, Georgia, Indiana, Kansas, Missouri, Oklahoma,
South Carolina, Texas, and Utah (expired July 2014).
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No health insurance issuers or consumers appear to have access to
the increased flexibility that could be afforded by state laws related
to the sale of health insurance coverage across state lines.
II. Solicitation of Public Comments
HHS solicits public comments about actions that could further
facilitate selling individual health insurance coverage across state
lines. Comments are requested in response to the questions below with
respect to individual health insurance coverage. The Administration
recognizes and strongly supports the fundamental role states play in
regulating insurance. Providing states with flexibility to address the
unique needs of their health insurance markets is a key component of
achieving the goals stated in the Executive Order. This RFI is not
intended to inform policy which will preempt state law or otherwise
impede the role states play as the primary regulators of insurance.
A. Expanding Access to Health Insurance Coverage Across State Lines
1. What are the practical advantages and disadvantages of allowing
health insurance issuers to sell individual health insurance coverage
across state lines through Health Care Choice Compacts?
2. What actions could the federal government undertake to
facilitate the state implementation of the sale of individual health
insurance coverage across state lines pursuant to section 1333 of the
PPACA?
3. While four states have passed laws specifically authorizing the
sale of individual health insurance across state lines, we understand
that no action to implement these laws has been taken. Additionally,
nine states have enacted laws authorizing the creation of Interstate
Health Compacts, yet we understand that no such Compact has been
created. Why have states not taken advantage of these opportunities?
Are there federal or state statutory and/or regulatory barriers that
prevent states from doing so?
4. Should HHS promote the sale of QHPs through Health Care Choice
Compacts across state lines and why?
5. How would the sale of individual health insurance coverage
across state lines through Health Care Choice Compacts impact access to
QHPs? We are particularly interested in the impact on counties that do
not have many options for QHP coverage in their current markets and
whether the sale of health insurance coverage across state lines would
increase or decrease the number of issuers offering QHPs in these
counties.
6. Are there mechanisms, such as memoranda of understanding or
other contractual arrangements, other than Health Care Choice Compacts
established pursuant to section 1333 of the PPACA, that states could
utilize to facilitate the sale of individual health insurance coverage
across state lines? Would selling health insurance coverage such as
short-term, limited-duration insurance; state-regulated farm bureau
coverage; or insurance licensed by a state as defined under section
2791(d)(14) of the Public Health Service Act (PHS Act) (to include each
of the several states, the District of Columbia, Puerto Rico, the
Virgin Islands, Guam, American Samoa, and the Northern Mariana Islands)
\14\ to individuals pursuant to such state agreements help facilitate
the sale of individual health insurance coverage across state lines?
Consider whether the type of coverage is relevant to, or would impact,
the form or nature of the agreements utilized by states.
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\14\ On July 14, 2016, the CMS Administrator sent letters to the
territories stating the new market reforms in the PHS Act enacted in
title I of the PPACA are governed by the definition of ``state'' set
forth in that title, and therefore do not apply to issuers of health
insurance coverage in the territories. The letter states the
definition of ``state'' set forth in the PHS Act will apply only to
PHS Act requirements in place prior to the enactment of the PPACA,
or subsequently enacted in legislation that does not include a
separate definition of ``state'' (as the PPACA does). This analysis
applies only to health insurance that is governed by the PHS Act.
The PHS Act, the Employee Retirement Income Security Act (ERISA),
and the Internal Revenue Code (Code) requirements applicable to
group health plans continue to apply to such coverage. The letters
are available at https://www.cms.gov/CCIIO/Resources/Letters/#HealthMarketReforms.
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B. Operationalizing the Sale of Health Insurance Coverage Across State
Lines
1. Is the structure of Health Care Choice Compacts contemplated by
section 1333 of the PPACA effective in facilitating the sale of
individual health insurance coverage across state lines? To date, no
states have passed laws specifically authorizing the state to enter
into a Health Care Choice Compact under section 1333 of the PPACA. Why
have states not enacted such laws? Are there any necessary revisions to
section to 1333 of the PPACA that would facilitate the sale of health
insurance coverage across state lines?
2. How difficult is it for small and/or regional health insurance
issuers to develop provider networks in multiple states that could be
used for health insurance coverage sold pursuant to Health Care Choice
Compacts, and what are the causes of any such difficulties? For
individual market health insurance issuers that already have a national
provider network, what are the challenges for selling individual health
insurance coverage across state lines through Health Care Choice
Compacts? In what ways could the federal government facilitate
expanding and strengthening provider networks?
3. How would states allowing health insurance issuers to sell
individual health insurance coverage across state lines through Health
Care Choice Compacts (if the health insurance coverage only covers
health benefits in accordance with federal law and the laws of the
state where the coverage is written) impact access to and the
utilization of medical services?
4. What new and existing consumer protections are needed to protect
policyholders that reside in one state but purchase individual health
insurance coverage from a health insurance issuer in another state
[[Page 8660]]
pursuant to a Health Care Choice Compact? How would allowing health
insurance issuers to sell individual health insurance coverage across
state lines impact the ability of state regulators to assist consumers
or impact the ability of state courts to resolve legal disputes when
the policyholder resides in a state other than that in which the policy
was written, pursuant to a Health Care Choice Compact?
5. To what extent, if any, would the sale of individual health
insurance coverage across state lines pursuant to a Health Care Choice
Compact positively or negatively impact the following populations:
Persons with pre-existing conditions; persons with disabilities;
persons with chronic physical health conditions; expectant mothers;
newborns; American Indians and Alaska Natives and tribal entities;
veterans; and persons with behavioral health conditions, including both
mental health and substance use disorder conditions?
6. In general, which statutes or regulations of the issuing state
should apply to an individual market policy sold in another state
pursuant to a Health Care Choice Compact, and which statutes or
regulations, if any, of the state in which the policy is sold should
apply? To what extent should policies being sold in another state
pursuant to a Health Care Choice Compact be required to cover the
state-required benefits of that state, and to what extent should such
policies be required to cover the state-required benefits of the
issuing state?
C. Financial Impact of Selling Health Insurance Coverage Across State
Lines
1. What policies, including how premiums and rates are established
and reviewed, and how risk is pooled, should be in place with respect
to rating and pricing of health insurance coverage sold across state
lines pursuant to Health Care Choice Compacts?
2. What impact would the sale of health insurance coverage across
state lines pursuant to Health Care Choice Compacts have on health
insurance coverage premiums for purchasers of insurance across state
lines and for policyholders purchasing in-state insurance in the state
where the across-state-lines purchasers live or in the state in which
the issuer is located? Would the impact be different for policyholders
in different states?
3. What impact would the sale of health insurance coverage across
state lines pursuant to Health Care Choice Compacts have on
policyholders' out-of-pocket expenses? Would the impact be different
for different policyholders?
4. What impact would the sale of health insurance coverage across
state lines pursuant to Health Care Choice Compact have on a health
insurance issuer's operating costs?
5. What impact would the sale of health insurance coverage across
state lines pursuant to Health Care Choice Compacts have on market
participation in each state?
6. What impact would the sale of health insurance coverage across
state lines pursuant to Health Care Choice Compacts have on competition
and the viability of health insurance issuers that elect not to sell
health insurance coverage across state lines?
7. What impact would the sale of health insurance coverage across
state lines pursuant to Health Care Choice Compacts have on health care
cost growth and medical inflation?
8. What impact would the sale of health insurance coverage across
state lines pursuant to Health Care Choice Compacts have on
consolidation of health insurance issuers?
9. What impact would the sale of health insurance coverage across
state lines pursuant to Health Care Choice Compacts have on the market
risk pools of the states where the health insurance issuer is domiciled
and where the policyholder resides?
10. What impact would the sale of health insurance coverage across
state lines pursuant to Health Care Choice Compacts have on the size
and composition of the uninsured population?
III. Collection of Information Requirements
This document does not impose information collection requirements,
that is, reporting, recordkeeping or third-party disclosure
requirements. This RFI constitutes a general solicitation of comments.
In accordance with the implementing regulations of the Paperwork
Reduction Act (PRA) at 5 CFR 1320.3(h)(4), information subject to the
PRA does not generally include ``facts or opinions submitted in
response to general solicitations of comments from the public,
published in the Federal Register or other publications, regardless of
the form or format thereof, provided that no person is required to
supply specific information pertaining to the commenter, other than
that necessary for self-identification, as a condition of the agency's
full consideration of the comment.'' Consequently, there is no need for
review by the Office of Management and Budget under the authority of
the Paperwork Reduction Act of 1995 (44 U.S.C. 3501, et seq.).
IV. Response to Comments
Because of the large number of public comments we normally receive
on Federal Register documents, we are not able to acknowledge or
respond to them individually. We will consider all comments we receive
by the date and time specified in the DATES section of this preamble,
and, in the event we issue a subsequent document, we will respond to
the comments in the preamble to that document.
Dated: January 28, 2019.
Seema Verma,
Administrator, Centers for Medicare & Medicaid Services.
Dated: February 14, 2019.
Alex M. Azar II,
Secretary, Department of Health and Human Services.
[FR Doc. 2019-04270 Filed 3-6-19; 4:15 pm]
BILLING CODE 4120-01-P