Monday, January 11, 2010

The NAIC's role in health care reform

Do you ever wonder how all the changes required by both the Senate and House reform bills will be implemented (assuming they become law)? Do you envision dozens and dozens of federal and state workers, busily crafting new regulations and procedures?

If so, remember that those government workers will have some help from the National Association of Insurance Commissioners. The NAIC is a voluntary organization of the chief insurance regulatory officials of the States. First established in 1871, the NAIC has a long history of developing model insurance laws that have enjoyed widespread adoption by the States.

In several instances in both the House and the Senate bills, Congress directs new initiatives to be developed in conjunction with guidelines or model laws developed by the NAIC.

In H.R. 3590, the Senate calls on the help of the NAIC in these areas:

--Under Act Sec. 1001 (adding new PHSA Sec. 2715), the Secretary of Health and Human Services must consult with NAIC (among others) to develop new uniform explanation of coverage documents;
--Under Act Sec. 1311, HHS must also consult with NAIC as it develops standards for the State Exchanges;
--Under Act Sec. 1333, the NAIC would help HHS create a framework for interstate health insurance compacts, which would be designed to facilitate the purchase of individual health insurance coverage across state lines (the House bill contains a similar concept at Sec. 309);
--Under Act Sec. 1341, the NAIC is tasked with helping HHS develop model regulations to govern a transition reinsurance program for the individual health coverage markets in each State; and
---Under Act Sec. 3210, the NAIC would aid in the development of new standards for certain Medigap plans.

In H.R. 3962, the House utilizes the NAIC’s help in the following ways:
---Under Act Sec. 101, the NAIC would help to develop the rates for premiums to be charged for coverage under the temporary national high-risk pool program;
---Under Act Sec. 243, the new Health Choices Commissioner is directed to consult with NAIC in the development of standards relating to access to affordable coverage and consumer protections;
---Under Act Sec. 309, the NAIC would help HHS create the framework for interstate health insurance compacts (similar to the concept in the Senate version discussed at Act Sec. 1333); and
---Under Act Sec. 1173, the NAIC would help to develop standards for reporting on the administrative costs of Medicare Advantage plans.

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