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From Health Reform WK-EDGE, January 31, 2019

CMS proposes summer deadlines for rate filings

By Kayla R. Bryant, J.D.

After issuers submit proposed rate filings, CMS will make the information available for consumer review. Final rate information will be posted November 1, 2019.

The proposed due date for filing justifications for single risk pool coverage in individual and small group markets for 2020 coverage is dependent on the presence of a state’s effective rate review program. States without an effective review program would be required to submit rate filings to CMS by June 3, 2019, while states with an effective rate review program can wait until July 24, 2019. CMS proposes posting information for consumer review on August 1, 2019 (CMS Letter, January 17, 2019).

Rate filings. The proposed timelines apply to single risk pool coverage for both qualified health plans (QHPs) and non-QHPs for plan or policy years effective on or after January 1, 2020. These deadlines apply to coverage with no rate changes, rate decreases, and rates for new coverage.

  • June 3, 2019: rate filings due for issuers in states without an effective rate review program;
  • July 24, 2019: rate filings due for issuers in states without an effective rate review program;
  • July 24, 2019: QHP rates table templates due for issuers submitting QHP applications for participation in federally-facilitated exchanges;
  • August 1, 2019: CMS posts information on proposed rate filings;
  • August 21, 2019: issuers must finalize all rate filings containing QHPs;
  • October 15, 2019: issuers must finalize all rate filings that contain only non-QHPs; and
  • November 1, 2019: CMS posts final rate information.

State wishing to release rate filing information earlier than the date CMS intends to post information must notify CMS at least five business days prior to making the information publicly available. CMS will conduct a final data refresh prior to posting information, and will post rate filing information for all issuers simultaneously.

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