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Hey, everybody.
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Welcome to Regulatory Joe.
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I'm Joe Boyle, president of ClearFile,
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and on today's episode, we'll be
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discussing how health plan benefit changes
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impact rate, form, and binder filings.
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So it actually can be hard sometimes
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to remember as a filer that individual
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benefit changes don't just live in
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one, two, three, but sometimes even
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more ancillary filings outside of
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your traditional form rate and binder.
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So a seemingly small change, such as a
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deductible PCP or specialist copay, or
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even a PT, OT, ST, or chiropractor visit,
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moving that five or even ten dollars,
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making that decision in a box and applying
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it only to one filing, not all, or having
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that dependent accountability matrix
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for all your stakeholders downstream
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could create a lot of problems for the
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filing process at any point of the year
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So let's actually define what
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types of filings there are.
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So starting with the rate filing.
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A rate filing is really composed
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of all the principles, artifacts,
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templates, tools, and instructions
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that set the premium rate for the plan.
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That is the price that the member
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will pay, and less what it would have
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included a couple of years back is
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applicability of advanced premium tax
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credits and all those different scenarios.
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But then again, all those factors that
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really include your formulary, your
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network, your benefit cost share and
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copay, and there are actually ten primary
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benefit drivers, your essential health
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benefits, and a subset of that, that
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drives your actuarial value and price.
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So again, rate filing really sets the
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price of the premium for the member.
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And then when we look at filings such
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as the form filing this is really
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the member contract and the binding
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agreement that essentially enforces
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the contracts within the form filing.
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And again, the anatomy of a form filing
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is, again, the acronyms are EOC, SBC,
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and SOBs, the three primary, what we
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call at ClearFile, anchor documents.
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Evidence of coverage, summary of benefits,
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summary of benefits and coverage.
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All standardized documents with company
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specific information that's unique
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to that plan and product strategy.
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And then finally, the binder filing, which
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some may consider to be the one that ties
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everything all together, is a compilation
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of the seven core CMS templates.
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That's your plan and benefit template,
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which is the largest functional
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document that drives that filing.
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But then again, the data-driven
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Excel components such as your anchor
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pharmacy benefit template, network
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template, service area, and even
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rating business rules and your URRT.
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Through the process of associations,
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filers must associate your form
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filing and your rate filing to
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the binder through the binder.
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So whoever your author is to the binder
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must hold actually the final process
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of tying together your HIOS plan IDs to
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making sure that those contracts and those
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premium rates reflect in the seven core
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templates against those HIOS plan IDs for
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submission and final plan certification.
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And while we do know that some
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divisions of insurance have limited
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resources, we do see that there
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is a little crossover between how
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binders and forms are reviewed.
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Sometimes every now and then you
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get the same reviewer reviewing your
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member contracts that's reviewing
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your actual benefit template.
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But then again, traditionally speaking,
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we need to go into every single plan year
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under the assumption that each individual
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filing, your rate, your form, and your
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binder will have an individual reviewer.
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So we also recommend in how we staff here
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at ClearFile is having dedicated filers,
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and again, by state, by company carrier.
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So making sure you have that single line
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of defense and also management of benefit
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changes to your rates, forms, and binders
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throughout every month of the year.
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So we can dive just a little bit
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deeper and talk about how this works.
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Let's use a very simple example, like the
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modification of an individual deductible
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from two thousand dollars to let's
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just say twenty-five hundred dollars.
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Doesn't actually matter as to why
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you're changing that benefit for the
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purpose of this scenario, whether it's
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controllable or uncontrollable, whether
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it's a federally mandated change or
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if it's a company strategy change.
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Generally speaking, once that decision
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has been enforced, we really need
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to understand, if it hasn't been
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already, an assessment of the impact.
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So the first area that we look at is
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generally the rate filing, because
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as you're modifying your benefits and
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setting your product portfolio, everything
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really revolves around the price.
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So as you make a benefit change,
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you always have to assume,
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until it's precluded, that
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your rates will be impacted.
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Now, at this time, we know that a
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deductible change can be found in a
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number of different materials that
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cascade not just across the rate filing,
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whether it's in the unified rate review
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template, the rate data template, or even
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ancillary documents like your actuarial
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memo, which is a narrative that will
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describe individual values of any benefit
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that's changed or remaining unchanged.
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And like we just talked about, we
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know that even if we did identify the
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actuarial specific documents that hold
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that individual deductible that we
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know is going to change, we as a filer
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already know that there's a handful
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of rate filing documents that are
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already included in the binder filing.
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So we need to make sure that we're
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including the filers and the available
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resources that are working with those
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respective reviewers to make sure all the
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documents and dependent documents from
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the rates and binders are accounted for.
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And again, as a third step, triaging
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and including your form filing experts
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to make sure the contract written
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language reflects the hard-coded benefit
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changes in your hard-coded filings.
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So we do that through what we call red
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line process, making sure that your
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documents and materials and contracts are
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always versioned with denoted changes, so
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you always know what's changing and why.
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So we can essentially look at the
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process in itself as a chain reaction
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or something like a snowball effect.
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One change impacting three core work
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streams, but you need to make sure
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that you have one final clean result
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that aligns with all the components.
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And it's important to understand that
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while we just talked through and used
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an individual deductible change as
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an illustrative example, which is
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common, it happens every single year,
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at a high volume, for that matter.
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Not all changes always have
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that same level of impact.
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So we can tell you one deductible
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change impacts price, but for example,
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if there's minimal or smaller co-pay
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changes for secondary benefits that are
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not in your primary benefit drivers,
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that actually may not impact your
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price or that may be rounded into the
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overall premium set by your actuary.
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So even though we understand one change
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one time, a second change or a third
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change or a fourth change can never
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be assumed to be handled the same way.
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So let's talk about how to
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manage benefit changes across
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all your filing work streams.
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Before anybody updates any filing for
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that matter, we recommend that in Q
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four of your current year or Q one
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of following plan year to really sit
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down and identify where your primary
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benefit drivers exist and display in
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each one of the respective plan filings.
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We call that a matrix
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and/or a benefit matrix.
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Now, we do know that there are
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hundreds and hundreds of benefits,
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that could be assumed within a filing.
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But based on the resources you have
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available to you and your teams and
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your company, we recommend starting with
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something as simple as your essential
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health benefits, those primary ten
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drivers, all the way down to your primary
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benefits, and then even if you're getting
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a groove down to your secondary benefits.
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This is not a process that will happen
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overnight, but we recommend parsing
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out your mapping and your matrix, over
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a timeline and a project schedule.
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So mapping out your benefits will allow
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your product strategists and your filing
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teams to truly understand what we call
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the anchor plans of a product portfolio.
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So again, we do know that how CMS has
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set up HIOS plan IDs is you do have your
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issuer ID, your product ID, your plan
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ID, and all those plans have variants.
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On an issuer or product level, you need
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to make sure the anchor plan or your base
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plan is a hundred percent accurate and
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has all those benefits that are intended
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and codified so that when variants are
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created, that's cascaded appropriately
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And again, we see the term used
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very differently across carrier
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partners, whether it's a marketing
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grid, a benefit grid, a cost share
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grid, or even a custom company name
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that defines your benefit grid.
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Having one single source and one plan
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design source, and again, you can even
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take it a step further in addition to
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versioning control, but having sign-off
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on that actual product portfolio by
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all the key stakeholders involved that
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memorializes your parent and child plans.
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We're big believers in
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accountability here at ClearFile.
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We believe in one accountable owner
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per body of work, or one accountable
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owner per particular type of filing.
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So we recommend assigning owners
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across your work streams to
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manage how benefits will impact
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your rates, forms, and binders.
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Generally speaking, at a health issuer,
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it's pretty easy to identify who your
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subject matter experts are, as long as you
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can help organize those roles in having
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your staff dedicate the time to the right
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filings at the right part of the year.
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So when we talk about benefit changes,
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again, one benefit change applying to
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three filings with meeting one outcome,
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when you actually quantify the number
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of changes that actually occur on an
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annual refresh, when health plan issuers
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are making required or uncontrollable
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changes, it's not just one or two.
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We're talking about dozens, if not
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hundreds of benefit changes that
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issuers are making concurrently
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every single year, not even including
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the controllable changes that are
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driven by company strategy on top
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of federal and state legislation.
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Volumes get very high, and having a
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process, a business process, and like
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we talked about, a matrix would be
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critical, or else I think the only
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outcome is offering uncompliant plans
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within the health insurance marketplace.
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So at ClearFile, we do have
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a centralized repository that
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helps track not just changes, but
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dependent changes across filings.
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So we do believe that having not just
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communication, but I think the added
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value is centralized communication
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and documentation in addition to your
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traditional versioning control adds a
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lot of value, especially upon refresh.
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And as you continue forward filing
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in future plan years, all your final
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approved data in past plan years
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will remain constant, the same,
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easily accessible in the event of any
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questions or if you have to look back
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at that material from a prior year.
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And as a filer, we spend so much
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time reconciling a filing ahead
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of submission in that May and June
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timeframe, we've often seen that
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at a health insurance issuer, it's
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hard to reconcile and re-reconcile
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during the traditional objection
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and question benefit change process.
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So we encourage you to apply all the
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rigorous project management that health
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issuers go through in the first two
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quarters of the year, especially when
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you're reconciling your plans ahead
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of plan confirmation and approval.
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And finally, we need to encourage all
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filers and all our partners out there
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to confirm a path for late changes.
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The last thing you wanna do is issue
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a change that results in more changes
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that you didn't intend to offer.
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And I think the key takeaway here is
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that by having a strong filing process,
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that's gonna allow you to keep every
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benefit change controlled and trackable
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throughout the life cycle of your filing.
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Thanks everybody for listening in.
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Give us a like, give us a share,
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and we'll see you all next time
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Hey, everybody.
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Welcome to Regulatory Joe.
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I'm Joe Boyle, president of ClearFile,
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00:00:03,865 --> 00:00:05,192
and on today's episode, we'll be
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discussing how health plan benefit changes
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impact rate, form, and binder filings.
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So it actually can be hard sometimes
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to remember as a filer that individual
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benefit changes don't just live in
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one, two, three, but sometimes even
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more ancillary filings outside of
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your traditional form rate and binder.
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So a seemingly small change, such as a
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deductible PCP or specialist copay, or
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even a PT, OT, ST, or chiropractor visit,
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moving that five or even ten dollars,
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making that decision in a box and applying
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it only to one filing, not all, or having
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00:00:38,204 --> 00:00:40,085
that dependent accountability matrix
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00:00:40,380 --> 00:00:42,158
for all your stakeholders downstream
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could create a lot of problems for the
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filing process at any point of the year
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So let's actually define what
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types of filings there are.
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00:00:50,159 --> 00:00:51,582
So starting with the rate filing.
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A rate filing is really composed
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of all the principles, artifacts,
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templates, tools, and instructions
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00:00:57,261 --> 00:00:59,864
that set the premium rate for the plan.
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That is the price that the member
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will pay, and less what it would have
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included a couple of years back is
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applicability of advanced premium tax
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credits and all those different scenarios.
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But then again, all those factors that
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really include your formulary, your
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network, your benefit cost share and
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copay, and there are actually ten primary
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benefit drivers, your essential health
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00:01:20,867 --> 00:01:23,185
benefits, and a subset of that, that
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00:01:23,199 --> 00:01:25,490
drives your actuarial value and price.
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00:01:25,640 --> 00:01:27,627
So again, rate filing really sets the
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00:01:27,628 --> 00:01:29,762
price of the premium for the member.
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And then when we look at filings such
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00:01:31,353 --> 00:01:32,965
as the form filing this is really
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the member contract and the binding
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agreement that essentially enforces
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the contracts within the form filing.
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And again, the anatomy of a form filing
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is, again, the acronyms are EOC, SBC,
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00:01:44,346 --> 00:01:46,701
and SOBs, the three primary, what we
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call at ClearFile, anchor documents.
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Evidence of coverage, summary of benefits,
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summary of benefits and coverage.
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All standardized documents with company
56
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specific information that's unique
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00:01:56,832 --> 00:01:58,687
to that plan and product strategy.
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And then finally, the binder filing, which
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some may consider to be the one that ties
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everything all together, is a compilation
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of the seven core CMS templates.
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That's your plan and benefit template,
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which is the largest functional
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document that drives that filing.
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But then again, the data-driven
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Excel components such as your anchor
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pharmacy benefit template, network
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template, service area, and even
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rating business rules and your URRT.
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Through the process of associations,
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filers must associate your form
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filing and your rate filing to
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the binder through the binder.
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So whoever your author is to the binder
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must hold actually the final process
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of tying together your HIOS plan IDs to
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making sure that those contracts and those
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premium rates reflect in the seven core
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templates against those HIOS plan IDs for
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submission and final plan certification.
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And while we do know that some
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divisions of insurance have limited
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resources, we do see that there
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is a little crossover between how
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binders and forms are reviewed.
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Sometimes every now and then you
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get the same reviewer reviewing your
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member contracts that's reviewing
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your actual benefit template.
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But then again, traditionally speaking,
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we need to go into every single plan year
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under the assumption that each individual
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filing, your rate, your form, and your
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00:03:12,423 --> 00:03:15,135
binder will have an individual reviewer.
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So we also recommend in how we staff here
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at ClearFile is having dedicated filers,
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and again, by state, by company carrier.
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So making sure you have that single line
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of defense and also management of benefit
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changes to your rates, forms, and binders
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throughout every month of the year.
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So we can dive just a little bit
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deeper and talk about how this works.
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Let's use a very simple example, like the
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modification of an individual deductible
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from two thousand dollars to let's
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00:03:40,934 --> 00:03:42,397
just say twenty-five hundred dollars.
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Doesn't actually matter as to why
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you're changing that benefit for the
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purpose of this scenario, whether it's
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controllable or uncontrollable, whether
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it's a federally mandated change or
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if it's a company strategy change.
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Generally speaking, once that decision
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has been enforced, we really need
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to understand, if it hasn't been
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00:04:00,310 --> 00:04:02,633
already, an assessment of the impact.
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So the first area that we look at is
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00:04:04,484 --> 00:04:06,082
generally the rate filing, because
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as you're modifying your benefits and
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00:04:07,657 --> 00:04:09,909
setting your product portfolio, everything
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really revolves around the price.
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So as you make a benefit change,
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you always have to assume,
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until it's precluded, that
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your rates will be impacted.
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Now, at this time, we know that a
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deductible change can be found in a
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number of different materials that
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cascade not just across the rate filing,
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whether it's in the unified rate review
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template, the rate data template, or even
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ancillary documents like your actuarial
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memo, which is a narrative that will
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describe individual values of any benefit
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that's changed or remaining unchanged.
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And like we just talked about, we
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know that even if we did identify the
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actuarial specific documents that hold
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that individual deductible that we
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00:04:47,562 --> 00:04:50,160
know is going to change, we as a filer
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already know that there's a handful
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of rate filing documents that are
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already included in the binder filing.
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00:04:55,618 --> 00:04:56,800
So we need to make sure that we're
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including the filers and the available
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resources that are working with those
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respective reviewers to make sure all the
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documents and dependent documents from
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the rates and binders are accounted for.
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And again, as a third step, triaging
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and including your form filing experts
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to make sure the contract written
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language reflects the hard-coded benefit
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00:05:17,010 --> 00:05:19,214
changes in your hard-coded filings.
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So we do that through what we call red
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00:05:21,302 --> 00:05:23,096
line process, making sure that your
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documents and materials and contracts are
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always versioned with denoted changes, so
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you always know what's changing and why.
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So we can essentially look at the
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process in itself as a chain reaction
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or something like a snowball effect.
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One change impacting three core work
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streams, but you need to make sure
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that you have one final clean result
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that aligns with all the components.
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And it's important to understand that
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while we just talked through and used
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an individual deductible change as
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an illustrative example, which is
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common, it happens every single year,
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at a high volume, for that matter.
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Not all changes always have
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that same level of impact.
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So we can tell you one deductible
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change impacts price, but for example,
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if there's minimal or smaller co-pay
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changes for secondary benefits that are
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not in your primary benefit drivers,
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00:06:10,791 --> 00:06:12,372
that actually may not impact your
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price or that may be rounded into the
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00:06:14,484 --> 00:06:17,183
overall premium set by your actuary.
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So even though we understand one change
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one time, a second change or a third
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change or a fourth change can never
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00:06:23,647 --> 00:06:25,665
be assumed to be handled the same way.
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So let's talk about how to
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manage benefit changes across
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all your filing work streams.
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Before anybody updates any filing for
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that matter, we recommend that in Q
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00:06:34,377 --> 00:06:36,931
four of your current year or Q one
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00:06:36,960 --> 00:06:38,865
of following plan year to really sit
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00:06:38,865 --> 00:06:41,023
down and identify where your primary
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00:06:41,024 --> 00:06:43,705
benefit drivers exist and display in
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00:06:43,705 --> 00:06:45,328
each one of the respective plan filings.
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We call that a matrix
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00:06:46,429 --> 00:06:47,835
and/or a benefit matrix.
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00:06:48,193 --> 00:06:49,758
Now, we do know that there are
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00:06:49,761 --> 00:06:51,426
hundreds and hundreds of benefits,
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00:06:51,477 --> 00:06:53,846
that could be assumed within a filing.
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But based on the resources you have
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available to you and your teams and
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00:06:57,884 --> 00:06:59,935
your company, we recommend starting with
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something as simple as your essential
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00:07:01,361 --> 00:07:03,162
health benefits, those primary ten
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00:07:03,166 --> 00:07:05,274
drivers, all the way down to your primary
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00:07:05,275 --> 00:07:07,642
benefits, and then even if you're getting
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00:07:07,643 --> 00:07:09,560
a groove down to your secondary benefits.
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00:07:09,574 --> 00:07:11,964
This is not a process that will happen
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00:07:11,977 --> 00:07:14,004
overnight, but we recommend parsing
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00:07:14,023 --> 00:07:15,893
out your mapping and your matrix, over
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00:07:15,893 --> 00:07:17,817
a timeline and a project schedule.
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00:07:18,257 --> 00:07:20,432
So mapping out your benefits will allow
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00:07:20,433 --> 00:07:22,621
your product strategists and your filing
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00:07:22,621 --> 00:07:24,889
teams to truly understand what we call
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the anchor plans of a product portfolio.
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So again, we do know that how CMS has
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00:07:29,870 --> 00:07:32,247
set up HIOS plan IDs is you do have your
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issuer ID, your product ID, your plan
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00:07:35,210 --> 00:07:37,678
ID, and all those plans have variants.
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On an issuer or product level, you need
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00:07:40,202 --> 00:07:42,384
to make sure the anchor plan or your base
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00:07:42,412 --> 00:07:44,301
plan is a hundred percent accurate and
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has all those benefits that are intended
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and codified so that when variants are
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created, that's cascaded appropriately
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And again, we see the term used
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very differently across carrier
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partners, whether it's a marketing
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grid, a benefit grid, a cost share
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grid, or even a custom company name
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that defines your benefit grid.
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Having one single source and one plan
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design source, and again, you can even
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take it a step further in addition to
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versioning control, but having sign-off
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on that actual product portfolio by
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all the key stakeholders involved that
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memorializes your parent and child plans.
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We're big believers in
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accountability here at ClearFile.
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We believe in one accountable owner
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per body of work, or one accountable
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owner per particular type of filing.
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So we recommend assigning owners
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across your work streams to
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manage how benefits will impact
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your rates, forms, and binders.
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Generally speaking, at a health issuer,
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it's pretty easy to identify who your
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subject matter experts are, as long as you
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can help organize those roles in having
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your staff dedicate the time to the right
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filings at the right part of the year.
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So when we talk about benefit changes,
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again, one benefit change applying to
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three filings with meeting one outcome,
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when you actually quantify the number
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of changes that actually occur on an
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annual refresh, when health plan issuers
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are making required or uncontrollable
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changes, it's not just one or two.
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We're talking about dozens, if not
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hundreds of benefit changes that
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issuers are making concurrently
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every single year, not even including
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the controllable changes that are
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driven by company strategy on top
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of federal and state legislation.
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Volumes get very high, and having a
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process, a business process, and like
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we talked about, a matrix would be
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critical, or else I think the only
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outcome is offering uncompliant plans
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within the health insurance marketplace.
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So at ClearFile, we do have
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a centralized repository that
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helps track not just changes, but
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dependent changes across filings.
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So we do believe that having not just
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communication, but I think the added
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value is centralized communication
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and documentation in addition to your
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traditional versioning control adds a
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lot of value, especially upon refresh.
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And as you continue forward filing
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in future plan years, all your final
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approved data in past plan years
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will remain constant, the same,
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easily accessible in the event of any
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questions or if you have to look back
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at that material from a prior year.
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And as a filer, we spend so much
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time reconciling a filing ahead
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of submission in that May and June
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timeframe, we've often seen that
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at a health insurance issuer, it's
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hard to reconcile and re-reconcile
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during the traditional objection
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and question benefit change process.
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So we encourage you to apply all the
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rigorous project management that health
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issuers go through in the first two
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quarters of the year, especially when
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you're reconciling your plans ahead
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of plan confirmation and approval.
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And finally, we need to encourage all
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filers and all our partners out there
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to confirm a path for late changes.
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The last thing you wanna do is issue
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a change that results in more changes
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that you didn't intend to offer.
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And I think the key takeaway here is
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that by having a strong filing process,
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that's gonna allow you to keep every
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benefit change controlled and trackable
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throughout the life cycle of your filing.
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Thanks everybody for listening in.
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Give us a like, give us a share,
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and we'll see you all next time
