October 26, 2018
1332 Waivers, HRAs, Prescription Drugs, and More
This week a slew of new guidance, regulations, and proposals were released by the Trump Administration. Here’s a quick summary of the new regulations. Please note that Wakely will be releasing more in-depth write-ups on some key regulations soon. Follow @WakelyCG on Twitter and Wakely Consulting Group on Linked In to get notifications.
New 1332 Guidance (click here for full document)
- The Trump Administration released new guidance on what 1332 waivers will be accepted. The new guidance increases the flexibility states have. Changes to affordability/coverage requirements (only require availability of such coverage not purchase of coverage)
- This means states will be able to design 1332 waivers in which funds previously earmarked for APTC could be used to subsidize enrollees in short-term plans or AHPS.
- The key restraint is that the total number of individuals with coverage has to be equal or greater with a waiver than without.
Proposed HRA Rule
- The Trump Administration also released a new proposed regulation will allow group coverage employers to provide up to $1,800 per year (indexed to inflation) to reimburse an employee for certain medical expenses and premiums. In particular, it would allow employers to subsidize employees to purchase individual market coverage. This obviously has implication for the individual market risk pool and small group risk pool. The regulation would not be finalized at least until the Spring.
Medicare and Prescription Drugs
- President Trump announced that CMS planned to propose a demonstration in which Medicare Payments for Part B would shift to prices based on international prices. If enacted it would not have an effect until 2020. HHS said the plan would save Medicare $17 billion over five years. It also released a report comparing US and international prices for top Medicare Part B drugs President Obama’s Administration considered a similar demonstration but ultimately did not enact it and remains to be seen if this Administration will ultimately follow through.
- Seema Verma, at speech at the Brookings Institute, announced that Part D plans need to better incentivize utilization of generics. It’s possible that there will be additional announcements or regulations on this topic.
And a few other odds and ends....
North Carolina Medicaid
North Carolina’s Medicaid 1115 waiver was approved this week. North Carolina’s demonstration was touted by CMS Administrator Seema Verma, given that the waiver shifts North Carolina’s program to a managed care delivery system and includes new pilot programs interventions which are aim to address issues like housing instability, transportation and food insecurity, and interpersonal violence. You can read Verma’s comments here.
- The Health Cost Institute released a fascinating interactive on how prices differ between metro areas across the US. Given it a look here.
- For the first time in a decade, Medicaid enrollment was flat for FY 2018 and FY 2019. Medicaid spending was relatively steady. Both of these finds are expounded in a KFF report you can find here.