"The preamble to the proposed rule suggests several ways in which this could be done, but the basic idea is that the TPA would take responsibility for providing coverage, and in turn contract with an insurer in the individual market to provide the coverage. The insurer would in turn pass the cost of the coverage (which now will be a real cost since the insurer has no responsibility for covering maternity or any other health care costs) on to a federally facilitated exchange (FFE), which would offset the cost through a reduction in user fees — in other words, the insurer would receive a reduction in the user fee it otherwise owes to the FFE to cover both its costs and any administrative costs incurred by the TPA."That's just the summary. Where to begin....
I have never seen a contraception-only policy before; are they even legal to sell?
I need to find a carrier, send them eligibility on a regular basis, and not get paid for any of it?
I am going to be really pissed if some carrier has a data breach and exposes PHI or Red Flag Data and I have to deal with the cost for services I didn't get paid for; I haven't seen any mention of immunity.
Will MLR apply to these policies? I foresee a lot of work to provide a small dollar benefit. In fact, I could see the administrative cost being higher then the cost of the drugs.
And who gets the rebates?
"Insurers providing contraceptive coverage would be responsible for notifying plan participants and beneficiaries of the availability of the coverage using language found in the proposed regulation. The notice would be provided separately from any other plan information, generally on an annual basis."There starts the excessive administrative fee. Apparently single males would also need to be offered this policy and notice?
Fraud potential in this is huge: I don't see where anyone is asking the TPA to verify who these policies are being purchased for.
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