requirements also need to apply to any Exchange systems modifications and, as such, language to that effect should be added to this section. KP Draft 14.35.15.06E - We recommend that this section be modified .06E Comment not incorporated at this time. This regulation is to make clear that the scenarios whereby there could be less than specific to prorating rules, and not specific to instances where one month of coverage only can arise as allowed by federal prorating would be required requirements, for example under special enrollment periods and terminations. KP Draft 14.35.15.06G(1) dictates to carriers on where their standard 06G(1) not incorporated at this time. It is in the State’s interest that policy on payments and grace period should be on display. We program beneficiaries receive as much access to carrier policies as believe that this is ultimately a business decision that carriers possible should manage, and that the MHBE should align with the FFM requirements. KP Draft 14.35.15.10A(3) has not been included in the Letter to .10A(3) This subregulation refers to “About doctors in this plan” PDF Issuers. We request clarity on what this requirement is and that that is current displayed in Plan Shopping. While it is not a this requirement and all certification requirements are outlined in requirement currently, all issuers meet this perspective standard. the Letter to Issuers. KP Draft 14.35.15.12B – This requirement is new for carriers, and has .12B Comment not incorporated at this time. In alignment with was not in the Letter to Issuers. We urge MHBE to make this MHBE principles on affordability and quality it is important that optional for carriers or remove it all together. participating carriers supply this information to the Exchange. HEAU .05H .05H Comment incorporated Appears to have an internal citation error to COMAR 14.35.14.04. HEAU .06D .06D Comment incorporated Appears to have an internal citation error. HEAU .07A .07A Comment not incorporated. MHBE has clarified “new enrollees” as “enrollees newly effectuating coverage”. The regulation does not Requires a carrier to provide new enrollees an enrollment contemplate existing enrollees. information packet but what is in the packet is not defined and “new” enrollee is not defined. Consumers should receive
requirements also need to apply to any Exchange systems modifications and, as such, language to that effect should be added to this section. KP Draft 14.35.15.06E - We recommend that this section be modified to make clear that the scenarios whereby there could be less than one month of coverage only can arise as allowed by federal requirements, for example under special enrollment periods and terminations. .06E Comment not incorporated at this time. This regulation is specific to prorating rules, and not specific to instances where prorating would be required KP Draft 14.35.15.06G(1) dictates to carriers on where their standard policy on payments and grace period should be on display. We believe that this is ultimately a business decision that carriers should manage, and that the MHBE should align with the FFM requirements. 06G(1) not incorporated at this time. It is in the State’s interest that program beneficiaries receive as much access to carrier policies as possible KP Draft 14.35.15.10A(3) has not been included in the Letter to Issuers. We request clarity on what this requirement is and that this requirement and all certification requirements are outlined in the Letter to Issuers. .10A(3) This subregulation refers to “About doctors in this plan” PDF that is current displayed in Plan Shopping. While it is not a requirement currently, all issuers meet this perspective standard. KP Draft 14.35.15.12B – This requirement is new for carriers, and has was not in the Letter to Issuers. We urge MHBE to make this optional for carriers or remove it all together. .12B Comment not incorporated at this time. In alignment with MHBE principles on affordability and quality it is important that participating carriers supply this information to the Exchange. HEAU .05H Appears to have an internal citation error to COMAR 14.35.14.04. .05H Comment incorporated HEAU .06D Appears to have an internal citation error. .06D Comment incorporated HEAU .07A Requires a carrier to provide new enrollees an enrollment information packet but what is in the packet is not defined and “new” enrollee is not defined. Consumers should receive .07A Comment not incorporated. MHBE has clarified “new enrollees” as “enrollees newly effectuating coverage”. The regulation does not contemplate existing enrollees.
14.35.15-Comments-Chart-071918.docx