In the preamble to AHIP's Feb. 25 comments to CMS, Dan Durham, AHIP executive vice president for policy and regulatory affairs, presses regulators to keep the safe harbor policy in place for 2015. "Given the continued focus in 2015 on new regulations, technology, processes, and procedures, we urge CMS to continue to recognize good faith efforts regarding compliance in 2015," he says.
And the Final 2015 Letter is not the final word on rule changes for the public exchanges next year. "Some policies with operational implications in the Draft 2015 Letter to Issuers are not being finalized in this Final 2015 Letter to Issuers, with the intent to continue work to accomplish them," the CMS document states.
A CMS official said Wednesday that one area that remains targeted for possible rule changes is the collection of provider network data. The Final 2015 Letter states: "For future years, CMS is further considering appropriate formats for collection of provider network data, which would both enable CMS to review provider network adequacy and allow for the creation of a search engine function for consumers to find particular providers and provider types on HealthCare.gov."
Mark these dates
While noting "all dates are subject to change," the Final 2015 Letter sets a timeline for key dates for health plan applications to participate in the public exchanges. The milestones include the following: