Reposted from Georgians for a Healthy Future: https://healthyfuturega.org/2021/06/16/cms-requests-more-information-about-georgias-proposed-changes-to-private-insurance/

On June 3^rd, 2021, the Centers for Medicaid and Medicare Services (CMS) sent a letter to Governor Kemp requesting additional data on the potential impacts of the Georgia Access Model. The Georgia Access Model was put forward by Kemp in his 1332 private insurance waiver, and the model would end access to healthcare.gov for Georgia consumers.

CMS is requesting additional data from the state because they believe recent changes made by President Biden’s administration to the Affordable Care Act’s health insurance marketplace have made the state’s previous analysis outdated or inaccurate. The Biden administration’s changes include:

• The COVID Special Enrollment Period (SEP)—through August 15, 2021, almost any American who does not have health insurance through their job can enroll in health coverage at healthcare.gov or by phone at 1-800-318-2596;
• More generous and expanded eligibility for Premium Tax Credits (PTCs)—almost anyone who qualifies for coverage through the ACA is now eligible for a discount on their monthly premium; and
• Increased funding for outreach and marketing for the ACA marketplace and enrollment opportunities.

These actions have led to more Americans, and Georgians, enrolling in Marketplace coverage. In addition, CMS believes that ACA enrollment would likely remain higher through 2023, when the Georgia Access Model is slated to begin.

In the letter, CMS also reasons the increase in enrollment could change insurance market dynamics enough to reduce the private sector’s incentive to enroll consumers. CMS believes with fewer uninsured people to enroll, the private sector may be less motivated to reach uninsured individuals. The idea that the private sector will be incentivized to enroll consumers once the competition of healthcare.gov is gone is a crucial assumption of Kemp’s waiver.

Georgia must now respond with updated data that takes into account the new federal changes. The new data will allow CMS to ensure the Georgia Access Model meets the protections specified in Section 1332 of the Affordable Care Act. These protections are:

1. Coverage must be at least as comprehensive as Marketplace coverage;
2. Coverage and protections against high costs must be as affordable as Marketplace coverage;
3. A similar number of people must have coverage under the waiver as without it; and
4. The waiver can’t add to the federal deficit.

The state may also request to adjust the Georgia Access Model, as needed, to meet waiver requirements in light of the new federal policies.

Once Georgia submits the new data about the Georgia Access Model, Georgia consumers, health advocates, and other stakeholders will have a chance to comment on the proposal again. CMS announced in their letter that they will hold a 30-day comment period after they receive Georgia’s new data. GHF expects the comment period will begin in early July. We will be working with our Cover Georgia partners to help Georgia individuals, organizations, and advocates comment. Stay tuned for your opportunity to weigh in again!

In July 2020, Governor Brian Kemp asked the federal government to approve a plan that would make several changes to private insurance in Georgia. The Governor’s plan is made up of two parts: 1) Reinsurance—which would help to lower premiums for some Georgians; and 2) the Georgia Access model—which would force consumers to enroll in coverage through for-profit insurance companies and web brokers instead of the unbiased and centralized enrollment platform that consumers know and trust (healthcare.gov). Federal health officials are asking Georgians like you to weigh in on the Governor’s plan. The deadline to comment is September 16, 2020. Don’t miss your chance to say how this plan will affect you, your loved ones, and Georgians across the state. After you read this short blog, tell health officials what you think.

What’s in the plan

Reinsurance

Reinsurance is a tool that some other states have used to lower premiums for consumers and attract more insurers to their marketplaces. Georgia’s proposed reinsurance program is designed so that it would lower premiums more in regions that have higher insurance premiums. Southwest Georgia consistently has some of the highest premiums in the U.S. Georgia’s plan predicts that premiums may drop by 10% across the state, with rural areas seeing bigger drops than urban areas.

Georgia Access Model

In the second part of his plan, Gov. Kemp proposes to dismantle the Affordable Care Act’s (ACA) health insurance marketplace (healthcare.gov). Georgians would no longer be able to enroll in health coverage through healthcare.gov. Instead individuals would be forced to enroll through a health insurer, web-broker, or a traditional broker.

Healthcare.gov is the most widely used and only unbiased place that consumers can shop for comprehensive health coverage. Consumers know all available plans will cover their health needs and they are offered financial help if they qualify and notified of their eligibility for Medicaid or other public coverage programs.

Under the Governor’s plan, Georgia consumers would be the only people in the U.S. forced to go without healthcare.gov, and instead rely on private entities for shopping and enrollment. For-profit insurance companies, online brokers, and even some insurance agents will display comprehensive, ACA-compliant plans alongside short-term plans or plans that do not cover all health services (like mental health and substance use services).

Impacts on Georgians with mental health & substance use conditions (and those in recovery)

Reinsurance: Could help make treatment & recovery services more affordable

The expected drop in premiums from the proposed reinsurance program will help to lower premiums for comprehensive health coverage (which cover mental health (MH) & substance use (SU) services), especially for rural consumers and consumers with incomes too high to qualify for the ACA’s financial help (>400% FPL). For consumers who need their coverage to access treatment services or to support their recovery, lower premiums will make it easier to afford their premiums and to cover their deductibles and other costs.

Georgia Access: Leaves consumers without access to treatment or recovery services

Under this plan, Georgia consumers will lose access to the most widely used enrollment pathway and its attached consumer assistance but will gain no additional enrollment options. Georgians are already permitted to enroll through insurers, web brokers, and agents.

Under an existing enrollment program run by the federal government, insurers and web-brokers have developed a track record of steering consumers toward substandard plans that expose them to catastrophic costs if they get sick; failing to alert or assist consumers when they are eligible for Medicaid; and making it difficult to compare plans. Because these companies are allowed to show substandard plans alongside comprehensive plans, the Georgia Access model will encourage Georgia consumers to enroll in substandard plans. Substandard plans are dangerous for Georgians with mental health and substance use needs because most do not cover mental health, and many do not offer substance use or prescription drug benefits. On top of that, substandard plans are allowed to exclude coverage for pre-existing conditions and charge more for people with pre-existing conditions like a history of mental illness or substance use.

The Georgia Access model puts Georgians at risk of getting lost in a confusing new enrollment process and becoming uninsured altogether. Georgians with little or no experience buying or using health insurance (e.g. young people), those with limited English proficiency, Georgians with low health literacy skills, and people with intellectual or cognitive disabilities would be at greatest risk of experiencing adverse consequences from the outlined plan.

Governor Kemp’s plan to change private health insurance in Georgia turns back the clock for Georgians with mental health and substance use conditions. Under this plan, Georgians would be at risk of enrolling in plans that do not cover their health needs and leave them to manage their recoveries with no help. As mental health and substance use issues rise as consequences of COVID-19, this plan moves Georgia in the wrong direction.

For what is likely the last time, health officials are asking for comments from Georgians about the Governor’s plan. The deadline to comment is September 16, 2020. Don’t miss your chance to say how this plan will affect you, your loved ones, and Georgians across the state! Tell health officials what you think today!