MODIFICATION
R -- Request for Information Outreach and Collection Activities under the Affordable Care Act (Previously RFI Regarding Reinsurance Program under ACA)
- Notice Date
- 4/10/2012
- Notice Type
- Modification/Amendment
- NAICS
- 524298
— All Other Insurance Related Activities
- Contracting Office
- Department of Health and Human Services, Centers for Medicare & Medicaid Services, Office of Acquisition and Grants Management, 7500 Security Blvd., C2-21-15, Baltimore, Maryland, 21244-1850
- ZIP Code
- 21244-1850
- Solicitation Number
- HHS-CMS-DBSC-RFI-11-621
- Archive Date
- 2/16/2012
- Point of Contact
- Brian J Humes, Phone: 410-787-8898
- E-Mail Address
-
brian.humes@cms.hhs.gov
(brian.humes@cms.hhs.gov)
- Small Business Set-Aside
- N/A
- Description
- Request for Information for Outreach and Collection Activities Under the Affordable Care Act SUMMARY: This is a revision of the request for information (RFI) published on December 16, 2011. It has been determined that the Federal government can utilize for-profit entities when the Department of Health and Human Services operates the transitional reinsurance program on behalf of a State. In order to streamline internal processes, this RFI seeks to gain market information on entities that could perform operational functions when HHS operates a transitional reinsurance program on behalf of a State. These functions include outreach and collection of contributions for a transitional reinsurance program, and reconciliation and invoicing for over-payments, charges and user fees for the Federal Exchange Programs System (see Appendix A for detailed information). This RFI will inform one or more future Requests for Proposals (RFP). DATES: Submit written or electronic comments by April 25, 2012. BACKGROUND: The Patient Protection and Affordable Care Act of 2010 was enacted to assist millions of Americans in obtaining affordable health care services and to allow more employers to offer insurance coverage in a cost effective manner to their employees. The Center for Medicaid and Medicare Services (CMS) within the Department of Health and Human Services (HHS) is responsible for management and oversight of the Affordable Care Act. Within CMS, the Center for Consumer Information and Insurance Oversight (CCIIO) has been created to ensure successful implementation, and adherence to, the specific provisions of the legislation. The final rule, Patient Protection and Affordable Care Act; Standards Related to Reinsurance, Risk Corridors and Risk Adjustment [CMS-9975-F], for the various premium stabilization programs was issued on March 23, 2012, and can be found at http://www.regulations.gov/#!documentDetail;D=HHS_FRDOC_0001-0448. The financial management program functions reside within CMS/CCIIO's Payment Policy and Financial Management Group (PPFMG). PPFMG's programs and responsibilities include collections of contributions for the reinsurance program; calculations and disbursement of payments for the reinsurance program; calculation and disbursement of payments/collection of charges for the risk corridor and risk adjustment programs; user fee collections for the risk adjustment program and Federally-Facilitated Exchange (FFE) operations; monthly processing and reconciliation of advance payments of the premium tax credits (APTCs) and cost sharing reductions (CSRs); and, remitting monthly aggregated payments. This RFI focuses on the collections of contributions required for the reinsurance program, as well as, reconciliation and invoicing for over-payments, charges and user fees in all of the PPFMG operational areas as identified above. This RFI solicits information from entities that could perform all actions pertaining to collections within the transitional reinsurance program, including, but not limited to, outreach to issuers, self insured plans and third party administrators (TPAs) required to contribute to the reinsurance program and State's reinsurance entities; review and reconciliation of reinsurance funds; allocation and tracking of allocated funds; reporting of reinsurance collections/allocations/discrepancies; and, fund distribution to states managing their own reinsurance program. In addition, this RFI solicits entities that could manage the invoicing and collections process for all of the PPFMG functions, to include, but not limited to, outstanding reinsurance contributions, outstanding risk adjustment user fees, FFE operations user fees, improper payments and charges. For all tasks mentioned, the following items would need to be completed: periodic reporting, ensure all collections transactions are securely documented, and that all collections transactions are validated within the system. All processes would require interaction and coordination with other Federal agencies, as well as, other CMS/CCIIO contractors. For further information on all programs for this RFI, please refer to Appendix A. We note that responses to this RFI are not offers, and cannot be accepted by the Federal government to form a binding contract or to issue a grant. The purpose of this RFI is to inform one or more Requests for Proposals. Information obtained in response to this RFI may be used by the Federal government for program planning and development, or other purposes with or without attribution. Do not include any information that might be considered proprietary or confidential. QUESTIONS: This RFI seeks comment from entities that can perform outreach, collections, invoicing, bookkeeping, and reporting activities. CMS may enter into one or more contracts to fulfill the statutory, regulatory, and operational requirements of the programs established under section 1341 of the ACA depending on the workload and number of States that would require assistance. In such a case, the contractor may be tasked with one or more of the following functions: • Outreach to the insurance market for the reinsurance program; • Collections and allocations (internal and external to the Federal government) of reinsurance contributions and user fees, to include remitting insurance market contributions to States when applicable; • Validation of issuer self-reported data; • Reconciling of expected/reported vs. actual monies remitted for contributions and invoices; • Invoicing management to include monitoring for paid/unpaid invoiced amounts and/or contributions and user fees; • Debt collection activities per the Federal debt collection process; • Bookkeeping for all collections, to include contributions allocations and receipt of invoiced amounts; • Periodic and ad-hoc reporting; and, • Providing customer support to issuers for collections and invoicing. CMS is seeking to engage formally, in a transparent and participatory manner, with entities that understand outreach and collections, and would be able to perform the responsibilities under the statute and associated regulations. In carrying out these activities, CMS seeks to mitigate conflicts of interest (COI) that may arise if potential market competitors perform the outreach and collection activities. As such, we request any information on potential COIs, and potential avenues for mitigation, from all stakeholders, including issuers and third-party administrators. INFRASTRUCTURE (1) Does your organization operate nationally or in limited geographic areas? If the latter, what are the geographic areas? (2) What potential COIs could arise if your organization were to perform the activities mentioned above? How might these COIs be mitigated? (3) For organizations that do not currently have COI mitigation programs, what steps would have to be taken to develop and execute such a program? (4) What is a reasonable amount of time for your organization to become fully operational (e.g., have all systems and standard operating procedures in place) after the date of a contract award? What resources would be necessary? (5) What services related to the collection of reinsurance contributions, or disbursement of reinsurance payments to another entity would your organization need to subcontract due to a lack of capacity, expertise, or experience? (6) Does your organization have experience with tracking and reconciling monies? If yes, please provide examples, including complexities. (7) What is your organization's present process, or planned process, for collecting and reporting on delinquent debts? CUSTOMER SUPPORT AND OUTREACH (8) What telecommunication and technical support systems does your organization currently maintain for health insurance issuers or other commercial clients (e.g., websites, 24-hour hotlines, helpdesk)? (9) Are your support systems compliant or have the capability of being Section 508 compliant <http://www.section508.gov/>? (10) Would your organization need to subcontract any services related to customer support and outreach? If yes, would multiple subcontractors be required? What type of oversight would you perform? (11) What COIs could arise for such subcontractors? (12) Does your organization have experience in producing outreach campaigns for short-term and long-term? What methods do you utilize? How successful are these methods? Please provide examples. (13) What process would your organization put into place in order to accurately review each new issuer/TPA in comparison to an official listing of verified issuers/TPAs to ensure validity? (14) How would your organization go about communicating and resolving issues of unpaid or underpaid contributions and/or RA user fees with applicable entities? Please note that these contributions and user fees would be self-reported by the issuer. DATA COLLECTION (15) Describe current data systems that are used by your organization, including any standards, security systems, and web-based interactive structure. Are your systems compliant or have the capability of being Section 508 compliant <http://www.section508.gov/>? (16) Do your organization's current data systems have the capability to interface with external systems to accept data and reports? If yes, what types of interfaces are currently in place? (17) In what formats does your organization currently collect data? Can your organization support other formats? If so, which ones? (18) Would your organization need to subcontract any services related to data collection? (19) What COIs could arise for such subcontractors? EVALUATION AND DATA VALIDATION (20) Does your organization currently conduct evaluations of operations and activities? (21) Do such evaluations include a financial assessment of your organization's activities? (22) What are your organization's current financial and data reconciliation processes? (23) What is your organization's present approach with regard to resolving data discrepancies, both outbound vs. inbound? APPENDIX A: The following is a brief overview of the FEPS and the programs contained within. Federal Exchange Programs System Overview An Exchange is a State-based competitive marketplace where individuals and small businesses will be able to purchase affordable private health insurance. There is no one-size-fits-all approach, and each State has the opportunity to tailor its Exchange to meet its needs. Exchanges will serve as a one-stop shop where individuals will get information about their options, be assessed for eligibility for the Exchange, tax credits for private insurance, or programs like the Children's Health Insurance Program, and enrolled in the plan of their choice. Small businesses will also have the option to purchase insurance through a program, the Small Group Health Options Program (SHOP), offered by each Exchange. For States that choose not to run an Exchange, HHS will run one on their behalf, known as the Federally-Facilitated Exchange (FFE). The data processing activities required to run the FFE, support State-based Exchanges (SBEs) and to operate programs associated with the FFE and SBE is known as the Federal Exchange programs system (FEPS). The main functions of an Exchange, laid out in the Affordable Care Act, include: • Certifying, recertifying, and decertifying health plans offering coverage through the Exchange, called qualified health plans; • Assigning ratings to each plan offered through the Exchange on the basis of relative quality and price; • Providing consumer information on qualified health plans in a standardized format; • Creating an electronic calculator to allow consumers to assess the cost of coverage after application of any advance premium tax credits and cost-sharing reductions; • Operating an internet website and toll-free telephone hotline offering comparative information on qualified health plans and allowing consumers to apply for and purchase coverage if eligible; • Determining eligibility for the Exchange, tax credits and cost-sharing reductions for private insurance, and other public health coverage programs, and facilitating enrollment of eligible individuals in those programs; • Determining exemption from requirements on individuals to carry health insurance, granting approvals to individuals relating to hardship or other exemptions; and, • Establishing a Navigator program to assist consumers in making choices about their health care options and accessing their new health care coverage, including access to premium tax credits for some consumers. The following provides additional information for some of the processes and programs associated with the implementation of Exchanges and Exchange-related programs: Enrollment Data Interchanges with Issuers and States When an individual enrolls in the FFE, the FFE will send an enrollment transaction to the relevant issuer. Monthly, issuers and the FFE will exchange full enrollment files to verify the integrity of the enrollment transaction processing. When an individual enrolls in an SBE, the SBE will send the routine enrollment transaction to the relevant issuer, but will also send a copy of the enrollment transaction to the FEPS. Those transactions will be used to create a national master file of all Exchange enrollees in the FFE and all SBEs housed in the FEPS. This master file will be used in SBE and FFE enrollment application processing to determine if an existing enrollment needs to be terminated to execute a new enrollment. It will also be used to support the processing of Advance Premium Tax Credits (APTCs) and Cost Sharing Reductions (CSRs) for monthly payment from the FEPS to issuers. APTCs and CSRs The APTC will assist qualifying Individuals participating in the Exchange with premium payment amounts while the CSR will control and limit the cost burden for out-of-pocket spending for qualifying Individuals. The Exchange will determine the APTC and/or CSR of the qualifying Individual. The Exchange will record and submit this information to CMS via a transactional 834 so that monthly payments can be made on behalf of the qualifying Individual to the Issuer. CMS will also provide the Exchange with information regarding the payments made. The Issuers will receive monthly payments and monthly payment reports. Premium Payments The Exchange will collect monthly premium payment amounts from Employers participating in SHOP. The collected premiums will be aggregated and distributed to Issuers along with a monthly payment report. The Exchange will also track and reconcile any unpaid premiums for which it is responsible for collecting. User Fees Two types of user fees will be collected to support Exchange and Risk Adjustment operations. User fees will be collected from participating Issuers in the Exchange in order to cover the administrative costs associated with Exchange and Risk Adjustment operations. The participating Issuers will be invoiced based on an assessment formulate. Reinsurance The transitional reinsurance program is a temporary three-year program that runs from January 2014 through December 2016, with potential residual operational activities through 2018. Under statute, all health insurance issuers, including self-insured group health plans, must contribute a specified amount to support reinsurance payments to individual market issuers that cover high-cost individuals in non-grandfathered plans. The Affordable Care Act directs States to establish or enter into contract with one or more non-for-profit reinsurance entities to carry out a transitional reinsurance program. The final rule published in March 2012 clarifies that States, regardless of whether they establish an Exchange, may choose to establish a transitional reinsurance program or have HHS operate the program on behalf of the State State. The final rule also states that HHS will collect reinsurance contributions from all self-insured plans regardless of whether the program is established by HHS or the State. In addition, when the State runs its own reinsurance program, the State can elect for HHS to collect the fully-insured market contributions on behalf of the State. In the HHS-operated program, payables for reinsurance are assessed by using individual-market data provided by eligible issuers. Payables are determined by HHS's reinsurance parameters that consist of an attachment point, cap and contribution rate. After payments have been determined, the payment and a payment report will be sent to the Issuer. State-operated programs have the option of using the HHS parameters, or designing a specific set of parameters for use in their State. Risk Adjustment The risk adjustment program is a permanent program beginning in January 2014 that will be applicable for the individual and small group markets inside and outside of the Exchange. The risk adjustment program protects health insurance Issuers in the individual and small group market that attract higher than average risk populations. Under this program, charges are assessed to Issuers with lower than average risk enrollees, and payments are made to Issuers with higher than average risk enrollees. The Federal government will specify the federally certified risk adjustment model to be used to determine the risk levels of the plans. The charges and payments are determined by using individual and small group data provided by eligible issuers. Utilizing this risk adjustment model, CMS will assess the actuarial risk of plans, compare it to the State average actuarial risk, and determine charges and payments. This program is designed to be budget neutral, with payments to higher-risk plans equaling charges received from lower-risk plans. Risk Corridors The risk corridor program is a temporary three -year program from January 2014 through December 2016 that is applicable to qualified health plans (QHPs) offered inside and outside of the Exchange. Under this program, the Federal government shares profits and losses with plans, thus insulating those plans against unexpected risk due to inaccurate rate setting. Data for risk corridors will be collected from the State, the Exchange, and Issuers. This data will be used to determine the profits and losses of QHP issuers. The programs described above require financial transfers occurring periodically between different parties. These parties may include States, Reinsurance Entities, Exchanges, CMS, Issuers, and Employers, as well as, any other designated CMS contractors. Please submit all written responses to: Centers for Medicare & Medicaid Services Attn: Brian Humes, Contract Specialist Office of Acquisitions and Grants Management Acquisitions and Grants Group Division of Beneficiary Support Contracts Mailstop: C3-30-03 7111 Security Boulevard Baltimore, MD 21244 Point of Contact Name: Brian Humes, Contract Specialist Phone: 410-786-8898 Email: brian.humes@cms.hhs.gov Please note, CMS is not taking questions for this RFI.
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