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MCC Certification Program. May 14, 2009 Jamie Katz. MCC Determinations. Applications for MCC Determinations Single applications may request determinations for multiple plans, resulting in both approvals and denials Numbers to date:
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MCC Certification Program May 14, 2009 Jamie Katz
MCC Determinations • Applications for MCC Determinations • Single applications may request determinations for multiple plans, resulting in both approvals and denials • Numbers to date: • 262 plans approved and 11 denied (5 more plans awaiting denial due to cap on Rx) • 78 applications under active review (some may be for multiple plans) • 183 applications to be reviewed (some for multiple plans) and 132 plans from one carrier to be reviewed • One consulting firm will be submitting requests for certification for 1,000-2,000 plans • 40 actuarial attestations included with submissions • Many determined to have no MCC deviation (no Connector action necessary) • Approximately 2.5 FTEs of Connector personnel currently involved in the MCC determination process
MCC Determinations • Many phone calls and e-mails with carriers, employers, and brokers • Guidance given on application process and standards • Organizations told not to apply if plans will not meet MCC (e.g., if any of the broad range services not met) and not to apply if their plans do fully meet MCC • Examples of denials • No Rx • No mental health coverage
MCC Determinations Central issues: Do plans provide robust coverage for healthcare services comparable to Bronze; and Will potential financial exposure for most covered individuals exceed Bronze potential exposure? • Recent examples of robust plans with deviations deemed MCC compliant: • Caps on specific preventive care services in plans with low or no deductibles and low or no OOP maximum • Most frequently, a cap on routine adult physical exams of $200-$500 (but not on diagnostic screenings) • Mental health/substance abuse co-insurance not counted toward OOP maximums (2009 issue) • Co-pays exceed $100 and not counted toward OOP maximum (often a separate cap on these co-pays)
MCC Determinations • Recent policy issues • Continuing, infrequent submissions by unions of plans intended for part-time workers—most recently, plans submitted have relatively low annual limits so do not meet MCC; denial by Connector usually means plans scrapped • In a small number of cases, caps on Rx exist (e.g., $5,000-$25,00) • Staff plans to disallow these plans, even though they may have a higher actuarial value than some of the allowed plans
MCC determinations • Public concern with the standard still evident, but communications expressing unhappiness with MCC standards have dropped substantially • Employers making significant efforts to meet MCC standards • Staff is seeing a high degree of compliance • Out of state employers also trying to accommodate MCC standards in many instances