Tag Archives: CMS

CMS Finalizes 2018 Meaningful Use Requirement Flexibilities

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CMS revises 2018 meaningful use requirements

Revisions include a 90-day reporting period, exceptions for decertified EHR technology, and acceptable versions of certified EHR technology.

As part of a final rule for hospital inpatient reimbursement for 2018, CMS has also finalized a host of revision to the meaningful use requirements for eligible providers participating in the EHR Incentive Programs next year.

Chief among the revisions is the reduction of the EHR reporting period next year to 90 days for “new and returning participants attesting to CMS or their Stage Medicaid agency,” states the final rule to be published on August 14. The revised reporting period must comprise a continuous 90 days between Jan. 1, 2018 and Dec. 31, 2018.

According to the final rule, the motivation for finalizing revisions to meaningful use requirements in 2018 is “to continue advanced of certified EHR technology utilization, focusing on interoperability and data sharing.”

Many of the other finalized changes owe much to mandates included in the 21st Century Cures Act, such as an exception for Medicare payments adjustments for eligible professionals and hospitals affected by EHR decertification. For those providers unable to satisfy meaningful use requirements because their certified EHR technology is now or becomes decertify, they will be able to avoid meaningful use penalties (but also miss out on EHR incentives). EPs will have until Oct. 1, 2017 to submit their applications; hospitals, July 1, 2017 — barring further changes made by CMS.

Additionally, EPs who provide “substantially all” of their services in ambulatory surgical centers (ASC) will avoid Medicare payment adjustments in 2017 and 2018:

We proposed to define an ASC-based EP under § 495.4 as an EP who furnishes 75 percent or more (or alternatively, 90 percent or more) of his or her covered professional services in sites of service identified by the codes used in the HIPAA standard transaction as an ASC setting in the calendar year that is two years before the payment adjustment year. In addition, we proposed to use Place of Service (POS) Code 24 to identify services furnished in an ASC and requested public comment on whether other POS codes or mechanisms should be used to identify sites of service in addition to or in lieu of POS code 24. For the reasons discussed in section IX.G.4. of the preamble of this final rule, we are finalizing the definition of an ASC-based EP as an EP who furnishes 75 percent or more of his or her covered professional services in sites of service identified by POS 24.

As for the type of CEHRT required for meaningful use attestation, CMS has finalized a policy that allows eligible professionals to use 2014 Edition, 2015 Edition, of a combination of the two for the purposes of EHR reporting in 2018.

That being said, the federal agency determined that calls to revise meaningful use objectives and measures, meaningful use audits, the Merit-Based Incentive Payment System (MIPS), and CEHRT grant funding were beyond the scope of the final rule and therefore not met.

The federal agency faced considerable pushback from industry groups advocating for significant change to the EHR Incentive Programs. Last month, the American Hospital Association (AHA) called for the cancellation of Stage 3 Meaningful Use, which is set to begin in 2018. The association claimed that the phase’s meaningful use requirements were overly burdensome.

“These excessive requirements are set to become even more onerous when Stage 3 begins in 2018,” AHA stated in a letter to CMS. “They also will raise costs by forcing hospitals to spend large sums upgrading their EHRs solely for the purpose of meeting regulatory requirements.

Based on this final rule, the EHR Incentive Programs will carry on as planned.

Florida Medicaid managed care demonstration gets 5-year extension

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http://www.healthcaredive.com/news/florida-medicaid-managed-care-demonstration-gets-5-year-extension/448610/

Dive Brief:

  • CMS approved a five-year extension of Florida’s section 1115 demonstration of a capitated Medicaid managed care program and low-income pool to support uncompensated care.
  • The uncompensated care pool will receive about $1.5 billion annually, based on the most current data on hospitals’ charity care costs, according to an Aug. 3 letter from CMS Administrator Seema Verma to Justin Senior, secretary of the Florida Agency for Health Care Administration.
  • The Managed Medical Assistance (MMA) demonstration, which now runs until June 2022, is the first to include simplified reporting requirements. CMS said it will monitor progress toward state-selected benchmarks and partner with the state to develop a meaningful program evaluation.

Dive Insight:

The modifications are in line with President Donald Trump’s administration’s pledge to reduce what it sees as burdensome or duplicative state reporting activities and with the CMS’ commitment to partner with states to improve their Medicaid programs.

In a March 14 letter, HHS Secretary Tom Price and Verma reminded states they can apply for waivers that would allow for significant changes to their Medicaid programs. States must show their waiver promotes the objectives of the Medicaid program, but HHS has broad authority for approval and Price has indicated he intends to broaden their use.

The CMS had been winding down funding for the Florida program under President Barack Obama’s administration. Officials at the time said the state should expand Medicaid under the Affordable Care Act to help with uncompensated care costs. They gave Florida $600 million for the final year of the program, far less than the about $2 billion requested.

The amount of funding now being provided offers a pretty clear indication the CMS under Trump thinks Florida is on the right track without expansion.

More than 30 states currently have waivers. Alabama received CMS approval in February for a section 1115 demonstration waiver to shift a majority of its Medicaid beneficiaries into regional care organizations, akin to accountable care organizations. While there are other states using this strategy, Alabama is unique in that it’s being administered by provider-run nonprofit organizations rather than a major insurer.

Patient advocacy groups have voiced alarm at potential steep cuts to Medicaid. Trump’s proposed $4.1 trillion budget would slash $610 billion from Medicaid plus 20% of funding for the Children’s Health Insurance Program. Robert Greenstein, president of the Center on Budget and Policy Priorities, said Trump’s budget would increase the number of uninsured and narrow Medicaid benefits and eligibility. This would lead to higher uncompensated care costs for hospitals.

Whistleblowers: United Healthcare Hid Complaints About Medicare Advantage

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http://www.healthleadersmedia.com/leadership/whistleblowers-united-healthcare-hid-complaints-about-medicare-advantage?spMailingID=11626431&spUserID=MTY3ODg4NTg1MzQ4S0&spJobID=1220355933&spReportId=MTIyMDM1NTkzMwS2#

Die Whistleblower

 

The suit, filed by United Healthcare sales agents accuses the giant insurer of keeping a “dual set of books” to hide serious complaints about its services

United Healthcare Services Inc., which runs the nation’s largest private Medicare Advantage insurance plan, concealed hundreds of complaints of enrollment fraud and other misconduct from federal officials as part of a scheme to collect bonus payments it didn’t deserve, a newly unsealed whistleblower lawsuit alleges.

The suit, filed by United Healthcare sales agents in Wisconsin, accuses the giant insurer of keeping a “dual set of books” to hide serious complaints about its services and of being “intentionally ineffective” at investigating misconduct by its sales staff. A federal judge unsealed the lawsuit, first filed in October 2016, on Tuesday.

The company knew of accusations that at least one sales agent forged signatures on enrollment forms and had been the subject of dozens of other misconduct complaints, according to the suit. In another case, a sales agent allegedly engaged in a “brazen kickback scheme” in which she promised iPads to people who agreed to sign up and stay with the health plan for six months, according to the suit.

Though it fired the female sales agent, United Healthcare concluded the kickback allegations against her were “inconclusive” and did not report the incident to the Centers for Medicare & Medicaid Services, according to the suit.

Asked for comment on the allegations in the suit, United Healthcare spokesman Matt Burns said: “We reject them.”

Medicare serves about 56 million people, both people with disabilities and those 65 and older. About 19 million have chosen to enroll in Medicare Advantage plans as an alternative to standard Medicare. United Healthcare is the nation’s biggest operator, covering about 3.6 million patients last year.

The whistleblowers accuse United Healthcare of hiding misconduct complaints from federal officials to avoid jeopardizing its high rankings on government quality scales. These rankings are used both as a marketing tool to entice members and as a way for the government to pay bonuses to high-quality plans.

Medicare paid United Healthcare $1.4 billion in bonuses in fiscal 2016 based upon their high quality ratings, compared with $564 million in 2015, according to the suit. CMS relies on the health plans to report problems and does not verify the accuracy of these reports before issuing any bonus payments.

The suit alleges the bonuses were “fraudulently obtained” because the company concealed the true extent of complaints. In March 2016, for instance, the company advised CMS only of 257 serious complaints, or about a third of the 771 actually logged, according to the suit.

The suit was filed by James Mlaker, of Milwaukee, a sales agent with the insurance plan in Wisconsin, and David Jurczyk, a resident of Waterford, Wis., a sales manager with the company.

The suit says Jurczyk had access to “dual” complaint databases, described as “the accurate one with a complete list of complaints and more details of the offenses and the fraudulent, truncated one provided to CMS.”

Jurczyk “has direct, personal knowledge of dozens of cases in Wisconsin alone in which customer complaints raising serious issues were routinely determined and falsely documented as either “inconclusive” or “unsubstantiated” by the company, according to the suit. Overall, about 84 percent of complaints alleging major infractions, such as forging signatures on enrollment forms, were determined to be inconclusive or unsubstantiated, according to the suit.

According to Mlaker, one sales agent faced little disciplinary action even after allegedly forging a customer’s signature on an enrollment form. The customer was “shocked” to learn that the agent had enrolled him because he had told the agent he was “not interested and did not want to enroll,” according to the complaint.

As a result, according to the suit, CMS officials never learned of these customer complaints.

The two men said that in early 2013 they began noticing that investigations of serious customer complaints that previously would have been completed “swiftly” instead “were drawn out; little actual inquiry was made, or even worse, known facts were ignored and discounted to falsify findings,” according to the suit.

Complaints also brought “much fewer and less serious corrective or disciplinary actions,” according to the suit. According to the suit, United Healthcare took steps to encourage any members with complaints to report them directly to the company rather than to complain to CMS.

The unsealing of the Wisconsin cases comes as United Healthcare and other Medicare Advantage plans are facing numerous cases brought under the Federal False Claims Act. At least a half-dozen of the whistleblower suits have surfaced since 2014.

The law allows private citizens to bring actions to recover damages on behalf of the federal government and retain a share. The Justice Department elected not to take over the Wisconsin case, which could limit the amount of money, if any, recovered. United Healthcare spokesman Burns said the company agreed with that decision.

In May, the Justice Department accused United Healthcare of overcharging the federal government by more than $1 billion by improperly jacking up risk scores over the course of a decade.

Red October: CMS Details Process for Billions in DSH Cuts

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Image result for disproportionate share hospital payments

With Congressional delays in Medicaid disproportionate share funding cuts set to expire Sept. 30, CMS issues a proposed rule that details billions in reductions that will begin in 2018.

As the Senate tries repeatedly to repeal the Affordable Care Act, so far without success, CMS is moving ahead with detailing how cuts in disproportionate share funding will be administered under a political deal the hospital lobby agreed to in exchange for getting more people covered by health insurance under the ACA.

The first step of the DSH cuts, which were supposed to have been implemented in stair-step fashion beginning in 2014 and running through 2020, had been delayed by Congress until 2018 after hospitals successfully argued that uncompensated care costs weren’t declining as much as expected under the ACA.

The cuts will now begin in 2018 with $2 billion, with $1 billion in cuts added each year until 2024, when DSH payments will be cut by $8 billion. Another $8 billion in cuts is scheduled for 2025.

Cuts will total $43 billion over the eight years.

The proposed rule lays out the DSH Health Reform Methodology (DHRM) that will be used to implement DSH funding reductions by state, in an attempt to target more heavily hospitals that experience the least financial impact from uncompensated care.

The DHRM will incorporate several sources of data to determine the amount by which each state’s DSH funding will be reduced for each year, in an attempt to account for a variety of factors that influence the financial impact of uncompensated care burdens in each state.

The methodology must, according to CMS “impose a smaller percentage reduction on low-DSH states.”

The largest reductions will be imposed on states with the lowest percentage of uninsured during the most recent year data is available, to states that do not target their DSH payments to hospitals with high volumes of Medicaid inpatients and to states that do not target DSH payments to hospitals with high levels of uncompensated care.

Data that will influence the DHRM will include United States Census Bureau Data and Medicaid DSH audit and reporting data submitted by the states.

The proposed rule is open for public comment until August 28.

Medicare proposed changes would cut home health reimbursement

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http://www.healthcarefinancenews.com/news/home-health-agencies-concerned-about-cuts-proposed-medicare-payments?mkt_tok=eyJpIjoiTXpOa01qUXhaVGd5TnpkaiIsInQiOiJudFozOHVLS1VVNXZZRE42Y0RmTWdIZHpkOU0yNERUSmlXU0VCMlJDMEFyMmVTUUc4aVwvcXRVc0gzXC9ndUdJVjhHT1drZkkzdDhBVFhHZ3BHVjI1NmhIVHY1RmNXSENVdWtwb3RVVnVtaFNWbXNFdnBzb0JVenRcL1ZuR1p0MW0zRyJ9

Home health agencies could see decreases of $80 million in 2017 and $950 million in 2019.

Home health providers object to the Centers for Medicare and Medicaid Services’ proposed rule that would reduce Medicare payments by 0.4 percent, or $80 million, in 2018, and up to  $950 million in 2019.

The Partnership for Quality Home Healthcare is especially concerned about a groupings model proposal starting in 2019 that  would change the unit of payment from 60-day episodes of care to 30-day periods of care and places patients in payment groups based on how they fit in six clinical categories.

“CMS is proposing a major reform to home health reimbursement without having worked collaboratively with industry partners like the Partnership and we expect to be included in payment reform development going forward,” said Partnership Chairman Keith Myers. “We question whether CMS has the unilateral authority to make such a proposed change without action by Congress.”

CMS said the six clinical groups used to categorize 30-day periods of care are based on the patient’s primary reason for home healthcare.

The new model could result in a $950 million Medicare payment cuts for home health providers in 2019 if it is implemented in a non-budget neutral manner, according to Home Health Care News. If implemented in a partially-budget-neutral manner, it could reduce payments by $480 million, the report said.

CMS is not proposing a revision to the split percentage payment approach in the change to a 30-day period. However, the agency said it is proposing to phase-out of the split percentage payment approach in the future and is soliciting feedback now.

For 2018, Medicare payments to home health agencies would be reduced by 0.4 percent, or $80 million, based on the proposed policies, CMS projects.

The $80 million decrease reflects the effects of a $190 million increase from a 1 percent home health payment update, a $170 million decrease from a -0.97 percent adjustment to the 60-day episode payment rate to account for nominal case-mix growth, and a $100 million decrease due to the sunset of the rural add-on provision.

The Medicare Access and CHIP Reauthorization Act, or MACRA extended until Jan. 1, 2018 the rural add-on, which increased by 3 percent the payment amount otherwise made for home health services in a rural area.

Additionally, the proposed rule for 2018 refines the home health value-based purchasing model. It revises the applicable measure for receiving performance scores for any of the home health consumer assessment of healthcare providers and systems, or HHCAHPS.

The Partnership for Quality Home Health Care said it plans to release an analysis of the proposed payment model and its impacts on home health delivery.

The coalition is concerned that Affordable Care Act directives for high-risk beneficiaries to receive access to home health services would result in disproportionate cuts to provide the care if the payments are implemented as drafted.

Tuesday’s home health rule is among several proposals that reflect a broader strategy by CMS to relieve regulatory burdens for providers, support the patient-doctor relationship in healthcare and promote transparency, flexibility, and innovation in the delivery of care, CMS said.

“CMS is committed to helping patients and their doctors make better decisions about their healthcare choices,” said CMS Administrator Seema Verma. “We’re redesigning the payment system to be more responsive to patients’ needs and to improve outcomes. The new payment system aims to encourage innovation and collaboration and to incentivize home health providers to meet or exceed industry quality standards.”

CMS gives $2.4 billion boost to inpatient hospitals for fiscal year 2018 with final uncompensated care rule

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http://www.healthcarefinancenews.com/news/cms-gives-24-billion-boost-inpatient-hospitals-fiscal-year-2018-final-uncompensated-care-rule?mkt_tok=eyJpIjoiTXpOa01qUXhaVGd5TnpkaiIsInQiOiJudFozOHVLS1VVNXZZRE42Y0RmTWdIZHpkOU0yNERUSmlXU0VCMlJDMEFyMmVTUUc4aVwvcXRVc0gzXC9ndUdJVjhHT1drZkkzdDhBVFhHZ3BHVjI1NmhIVHY1RmNXSENVdWtwb3RVVnVtaFNWbXNFdnBzb0JVenRcL1ZuR1p0MW0zRyJ9

Inpatient hospitals will see increase of $800 million over the previous year, but long-term care facilities face $110 million cut in payments.

CMS Final Rule for the 2018 Medicare Inpatient Prospective Payment System will give hospitals an overall $2.4 billion raise in fiscal year 2018, the agency said.

Due to the combination of payment rate increases, other policy changes and adjustments acute care hospitals will see $6.8 billion in payments for uncompensated care, an increase of $800 million over the previous year, CMS said.

Medicare payments to inpatient psychiatric facilities will rise by $45 million, or roughly one percent. However, long-term care hospitals will decrease by $110 million in fiscal year 2018.

The changes will affect 3,330 acute care facilities and roughly 420 long-term care hospitals for discharges happening after October 1, 2017. The new rule incorporates CMS’ finalized proposal to use data from its National Health Expenditure Accounts in its estimate of the rate of uninsurance, which is used in calculating the total amount of uncompensated care payments available.

Long-term care hospitals will be facing a cut. Under the 2018 final rule, CMS projected payments will drop roughly 2.4 percent, or $110 million in FY 2018, which is “due in large part to the continued phase in of the dual payment rate system.” However, this amount is actually smaller than the previously projected cut of 3.75 percent, which was first proposed back in April.

CMS has also finalized its proposal for a one-year regulatory moratorium on the payment reduction threshold for patient admissions for long-term care hospitals in FY 2018 while they continue to evaluate the policy, CMS said.

CMS moves forward with $43B in DSH payment cuts

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http://www.beckershospitalreview.com/finance/cms-moves-forward-with-43b-in-dsh-payment-cuts.html

Image result for cutting currency

CMS issued a proposed rule Thursday that lays out a methodology for implementing cuts to Medicaid Disproportionate Share Hospital allotments under the ACA beginning in fiscal year 2018.

With the expectation of lower uninsured rates and lower levels of hospital uncompensated care, the ACA adjusted the amounts of funding available to states under the Medicaid program for hospitals that serve a disproportionate share of low-income patients. The ACA calls for aggregate reductions to Medicaid DSH payments annually from FY 2014 through FY 2020. Subsequent legislation delayed the start of the reductions until FY 2018 and pushed the end date back to FY 2025.

Medicaid DSH allotments are slated to be reduced by $2 billion in FY 2018. The reductions will grow by $1 billion per year through FY 2024, when payments will be cut by $8 billion. DSH allotments will be reduced by another $8 billion in FY 2025.

CMS proposed a methodology that would account for new data sources, some of which were unavailable during prior rulemaking. Those sources include DSH Medicaid Inpatient Utilization Rate data, U.S. Census Bureau data and existing state DSH allotments. “We are proposing to utilize the most recent year available for all data sources and are proposing to align data sources whenever possible,” said CMS.

The proposed methodology would help ensure DSH payments reach hospitals with the most need for financial assistance due to high volumes of Medicaid inpatients and high levels of uncompensated care, according to CMS.

CMS will accept comments on the proposed rule until Aug. 28 at 5:00 p.m.

Senate GOP Considers Taxing Employer Plans in Bill

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https://morningconsult.com/briefs/health-brief-senate-gop-considers-taxing-employer-plans-bill/

Image result for Senate GOP Considers Taxing Employer Plans in Bill

Washington Brief

  • Senate Republicans are considering taxing employer health insurance plans, but haven’t decided whether to include such a provision in a draft health care bill to repeal and replace major parts of the Affordable Care Act being crafted this week. (The Wall Street Journal)
  • The California State Senate advanced a bill to adopt a single-payer health care system on Thursday, but the measure does not include a way to pay for the $400 billion tab. (The Los Angeles Times)
  • Freedom Partners and Americans for Prosperity, conservative groups affiliated with the Koch Brothers, is urging HHS Secretary Tom Price to take action on “Phase 2” work that would undo parts of the ACA through regulation ahead of Congress passing a bill.

Business Brief

  • Premiums for policies sold on the individual market in Pennsylvania next year are set to increase by 8.8 percent on average, but the state’s insurance commissioner warned that could jump to a 36.3 percent increase if the Trump administration does not enforce certain aspects of the Affordable Care Act. (Lancaster Online)
  • Hospital leaders are concerned that President Donald Trump’s decision to withdraw from the Paris climate agreement could hurt peoples’ health. (Axios)
  • Health insurers participating in models to improve care for beneficiaries enrolled in both Medicare and Medicaid originally struggled to find participants, but new data from the Centers for Medicare and Medicaid Services shows many have overcome that challenge. (Modern Healthcare)

Post-acute care: Medicare Advantage vs. Traditional Medicare

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Post-acute care: Medicare Advantage vs. traditional Medicare

From a public spending point of view, post-acute care is particularly problematic. Most of Medicare’s geographic spending variation is due to this type of care. Part of the story is that Medicare pays for post-acute care in several different ways, with different implications for efficiency.

For example, traditional Medicare (TM) — which spends ten percent of its total on post-acute care — pays skilled nursing facilities per diem rates but inpatient rehabilitation facilities a single payment per discharge. Post-acute care is also available through Medicare Advantage (MA), which operates under a global, per-enrollee, payment. Unlike TM, MA plans establish networks, may require prior authorization for post-acute care, and can charge more in cost-sharing for post-acute care than TM does.

These different payment models offer different incentives that may affect who receives care, in what setting, and for how long. In Health Affairs, Peter Huckfeldt, José Escarce, Brendan Rabideau, Pinar Karaca-Mandic, and Neeraj Sood assessed some of the consequences of those incentives. Focusing on hospital discharges for lower extremity joint replacement, stroke, and heart failure patients between January 2011 and June 2013, they examined subsequent admissions to skilled nursing and inpatient rehabilitation facilities, comparing admission rates, lengths of stays, hospital readmission rates, time spent in the community, and mortality for MA and TM enrollees. To do so, they used CMS data on post-acute patient assessments for patients with discharges from hospitals that received disproportionate share or medical education payments from Medicare.

CMS Checklist For State 1332 Waivers Focuses On High-Risk Pools, Reinsurance

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http://healthaffairs.org/blog/2017/05/12/cms-checklist-for-state-1332-waivers-focuses-on-high-risk-pools-reinsurance/

On May 11, 2017, the Centers for Medicare and Medicaid Services and the Department of the Treasury released a checklist for state 1332 innovation waiver applications. Following up on Health and Human Services Secretary Price’s letter to state governors of March 13, 2017, the checklist specifically focuses on state 1332 proposals to support high-risk pools or reinsurance programs.

Indeed, the checklist begins by stating:

The Department of Health and Human Services and the Department of Treasury (the Departments) are interested in working with states on Section 1332 waivers that would lower premiums for consumers, improve market stability, and increase consumer choice. In particular we welcome the opportunity to work with states to pursue Section 1332 waivers incorporating a high-risk pool/state-operated reinsurance program. State-operated reinsurance programs have a demonstrated ability to help lower premiums, and if the state shows a reduction in federal spending on premium tax credits a state could receive Federal pass-through funding to help fund the state’s reinsurance program.

The checklist restates the procedural requirements that states must meet under the current 1332 rules, such as posting a notice of the waiver proposal and accepting comments for at least 30 days, holding two public hearings, and consulting with Indian tribes where relevant.

Most elements in the checklist, however, describe specifically what information states must submit with applications for a 1332 waiver involving a reinsurance or high-risk pool program. While states must generally document state legislative authority to operate a 1332 waiver program, a state seeking a waiver to operate a high-risk pool or reinsurance program must establish that the legislation makes the program contingent on 1332 waiver approval or that the program will only become operational if the waiver is approved. Otherwise, the state would not be able to establish that federal 1332 waiver pass-through funding was necessary for the program.

A state must specify the provisions of the ACA it proposes to waive, which might, a footnote explains, include the ACA’s single-risk pool requirement for a reinsurance or high-risk pool proposal. State 1332 waiver proposals must include economic and actuarial data and analyses documenting the effect of the proposal on coverage and on comprehensiveness and affordability of coverage. A reinsurance/high-risk pool proposal would have to describe a baseline of premiums and coverage without the waiver and then compare this to projections of coverage and premiums under the waiver.

Proposals for 1332 waivers must explain how they would affect federal budget neutrality. A state seeking a reinsurance or high-risk pool waiver must establish a baseline of federal expenditures without the waiver and then show how federal expenditures or revenues for premium tax credits, shared responsibility payments, exchange user fees, and health insurance provider fees would change if the proposal is implemented.

States must further submit a timeline for implementation. They must describe whether they would use a condition-based list for a reinsurance program or an attachment-point-based model and the incentives they would offer providers, insurers, and enrollees to manage health care costs and utilization. They must describe how the program would affect other provisions of the Affordable Care Act and how it would provide out-of-state coverage for those who need it. States must report the actual second-lowest-cost silver benchmark plan premium annually, as well as an estimate of what it would have been without the program. The checklist further states, “For comprehensiveness, if there is no change to the provision of the ten Essential Health Benefits (EHB) identified in the benchmark plan, the state can indicate that it will report on any modifications from federal or state law on an annual basis.”

In sum, the checklist provides a roadmap for states that want to pursue high-risk pool or reinsurance 1332 waiver proposals, indicating again the priority that the Trump administration places on this approach for increasing the affordability of health insurance coverage.