qhp issuer workshop part ii - arkansas...plan management updates meaningful difference • the...

QHP Issuer Workshop Part II

QHP Application and Review Process Overview, Part II

April 15, 2014

www.pcghealth.com

Schedule and Logistics

QHP Advisory Committee 2

Meeting Information

The meeting will be available in Webex. To join the meeting,

click here and enter meeting password ARQHP. The phone

number to for the voice conference is:

Call-in toll-free number (US/Canada): 1-877-668-4493

Access code: 766 660 437

Proposed Schedule

• 1:30pm – Start meeting

• 2:45pm – 15 Minute Break

• 3:00pm - Resume

• 4:15pm – Wrap up

https://pcgus.webex.com/pcgus/j.php?MTID=ma1d730574c3d5a6d6f31b0ce602f30c7

Agenda

QHP Advisory Committee 3

• Introductions

• Plan Management Updates

• AR 2015 QHP Filing and Certification Requirements

• Review of QHP Bulletin

• Recertification

• Uniform Modification Allowances

• Essential Health Benefits; new considerations

• Quality Improvement Initiatives

• Plan Variations

• Rate Filing

• CMS Review Tools

• Questions?

Plan Management Updates

QHP Bulletin

• The QHP Bulletin was released on Monday, April 14

2015 Final Letter to Issuers

• The 2015 final letter to issuers was released by CCIIO on

March 14 and summarizes plan year 2015 QHP

certification requirements

• The letter can be found here

Network Adequacy Rule

• The AID Network Adequacy rule is expected to be

published within the week (by April 22nd)

QHP Advisory Committee4

http://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/2015-final-issuer-letter-3-14-2014.pdf


• 2014 QHP Application and Certification Timeline – Part I

*AID is requesting that all plan changes be completed by August 6th

to allow time for transmission to HIOS


2014 Key Dates Description

May 1st – June 15th QHP Applications must be submitted to AID by

June 15th

June 16th – August 8th * AID QHP review period

August 11th–August 25th FFM Reviews Plan Data

August 26thFFM Notifies States of any Needed Corrections

to QHP Data

September 4th Last day for issuers to resubmit plan data

September 5th – September

10th2nd SERFF Data Transfer


• 2014 QHP Application and Certification Timeline – Part II


2014 Key Dates Description

September 22nd FFM Completes Re-review of Plan Data and

State Recommendations

September 24th– October 6th Limited Data Correction Window

October 14th– November 3rd

Certification Notices and QHP Agreements

Sent to Issuers, Agreements Signed, QHP Data

Finalized

November 15th Open Enrollment Begins


• Outstanding technical and policy updates that could

impact the timelines:

• Release of 2015 Plan Management Templates (CMS)

• Completion of updated SERFF validation services (expected by

late May)

• Final AID and Health Care Independence Program (“HCIP”,

a.k.a. “Private Option”) QHP certification criteria and details on

cost-sharing variations (expected by May 1)

• Changes to the proposed market standards for 2015 and beyond

(CMS)



Meaningful Difference

• The review process or meaningful difference in plans was

expanded for 2015 and changed slightly from the proposed rule.

• Plans will be segmented by plan type, metal level and

overlapping counties/service areas and then evaluated for

differences in network, formulary, deductibles, MOOP, covered

benefits, HSAs, and availability for children (premiums was taken

out as a criteria)

• Plans are expected to differ in at least one of these areas.

8


Summary of Benefits and Coverage (SBC)

• SBCs are required to be submitted for plan year 2015.

SBCs illustrate benefits and coverage for common

conditions chosen by HHS: Routine maintenance of well-

controlled type 2 diabetes and having a baby (normal

delivery)

• SBCs for plan variations are not required, but are

encouraged. SOBs must be accurate and match policy and

SOB’s information.

9


2015 Plan requirements

• Riders are not permitted to be offered in conjunction

with Marketplace plans, even if the riders are for non-

EHB benefits

• In addition to federal requirements that at least one

silver and at least one gold plan are offered in the

individual market, QHPs in the Arkansas individual

market are required to include at least one silver-level

plan that contains only the EHBs included in the state

base-benchmark plan


Filing and QHP Certification Requirements

QHP Application Process

• QHP applications will be filed through SERFF

• Rate and form filings must both be submitted by the QHP

application deadline (see timelines)

• Individual and small group plans that are only outside the

marketplace are not required to have submitted

applications by the June 15 deadline

• SAD issuers should submit both inside and outside

marketplace plans (that will be certified as a supplement to

EHB)

• SERFF will conduct Issuer trainings April 22-May 21



CMS Onsite Training

• QHP Certification Onsite Technical Assistance Session for

Issuers April 22-23 at CMS in Baltimore

• The purpose of this session is to provide the Issuers and

other entities with information needed for successful QHP

certification

• Register by Thursday, April 17



Recertification

• The CMS 2015 Final Letter to Issuers indicates that the

recertification process will largely resemble the initial

certification process and that all application materials must be

re-submitted

• A recertified plan can keep the same plan and HIOS ID, and

enrollees will remain enrolled into the new benefit year

• Plans that issuers are proposing to recertify will remain in

effect into the new benefit year unless the enrollee terminates

their policy

• Applications for recertification should include a redlined

version of the plan forms and a written justification for any

changes to cost-sharing and covered benefits (A template for

submission of plan change justifications will be posted in

SERFF)



Uniform Modification

• Plans with “uniform modifications” are allowed to be renewed and

recertified if the change is pursuant to Federal or state law, such as

increasing annual limitations on cost-sharing as a result of the

application of the premium adjustment percentage.



Uniform Modification

• If changes are made to the plan that not due to Federal and

state law, then they may still meet the uniform modification

criteria if the plan:

• Is offered by the same health insurance issuer and is the same

product type (i.e. PPO or HMO);

• Covers a majority of the same counties in its service area;

• Maintains the same cost-sharing structure, except for actuarial

adjustments that are a result of cost and utilization of medical

care or in order to maintain the same A/V level of coverage; and

• Provides the same covered benefits, unless changes to benefits

impact the rates only ± 2%.



Uniform Modification – FAQs

Q1: Do changes to plans such as inclusion of mandatory benefits

like TMJ and hearing aids, changes to a plan to meet the EHB-only

silver plan requirement, changes to HCIP cost-sharing

requirements, and removal of riders count as a uniform

modifications?

A1: These changes are pursuant to changes in federal and state

law and guidance and are considered uniform modifications

Q2: Will changes to non-EHB benefits violate uniform modification

criteria?

A2: If the changes to non-EHBs affect the plan index rate by more

than 2%, it will not be considered a uniform modification.



Uniform Modification – FAQs

Q3: To what extent is a change to MOOP allowed and it still be

considered pursuant to federal law (due to annual increase in

MOOP in the 2015 benefit and payment parameters)?

A3: CMS has recently indicated that in order to qualify as a uniform

modification, the change must be pursuant (required) by law, so a

change in plan MOOP due to annual increase in the maximum

allowable MOOP levels would not be considered a uniform

modification. AID is submitting comments on the proposed market

standards and will indicate this suggested clarification in the final

rule.



Certification Standards Applicable to Stand-alone Dental

Plans


Certification Standard Applies (* denotes modified standard)

Certification Standard Does Not Apply

Essential Health Benefits*

Actuarial Value* Accreditation

Annual Limits on

Cost Sharing*

Licensure Cost-sharing Reduction Plan Variations

Network

Adequacy

Inclusion of ECPs Unified Rate Review Template

Marketing Service Area Meaningful Difference

Non-discrimination


Associated Schedule Items

• QHP forms and associated documentation should be

attached to the binder through SERFF Plan Management

functionality. All applicable forms must be attached to the

correct plans in the binder.

• The SERFF instructions for associated schedule items can

be found here.


https://login.serff.com/Appendix II.pdf

Essential Health Benefits

• The QHP Issuer must offer coverage that is substantially equal to

the coverage offered by the state’s base benchmark plan and

attest that plans are in compliance with all EHB standards.

• Benefits and coverage requirements for the AR Benchmark Plan

can be found in the QHP Checklist and AR Essential Health

Benefits Guidelines (see Attachment D).



Mental Health Parity

• MHPAEA requires that treatment limitations (whether quantitative or non-

quantitative) for MHSA benefits are no more restrictive than the

predominant requirements or limitations applied to substantially all

medical/surgical benefits.

Mental Health Benchmark Requirements

• The AR benchmark coverage for mental health is based on the

QualChoice federal employee benefits health plan. However, the non-

quantitative treatment limitations in the mental health and substance

abuse benchmark plan may not meet the MHPAEA; issuers must ensure

that the quantitative and non-quantitative treatment limitations in MHSA

coverage comply with MHPAEA requirements.

• For example, the benchmark plan states that all services require

preauthorization and an approved treatment plan, and this would not be

permitted under MHPAEA unless the same limitation applies to substantially

all medical and surgical benefits in the benefit category.



Mental Health Parity and AR Network Adequacy Standards

• Network adequacy- Mental Health, Behavioral Health and

Substance Abuse access standard was previously 45 minutes or

45 miles. Due to updates in the mental health parity rule and

confirmation from CCIIO, the standard has been changed to 30

minutes or 30 miles. It is understood that in some areas of the

state, there are not sufficient providers to meet this standard.



Prescription Drugs

• CMS noted in the letter to issuers that the agency intends to

review plans that are outliers based on an unusually large

number of drugs subject to prior authorization and/or step therapy

requirements in a particular category and class.

• CMS also expects the URL link to direct consumers to an up-to-

date formulary where they can view the covered drugs, including

tiering, that are specific to a given QHP.

• The URL provided to the Marketplace as part of the QHP

Application should link directly to the formulary, such that

consumers do not have to log on, enter a policy number or

otherwise navigate the issuer’s website before locating it. If an

issuer has multiple formularies, it should be clear to consumers

which formulary applies to which QHP(s).



Arkansas Habilitative Services

Definition of Habilitative Services

• Habilitative services are services provided in order for a person to

attain and maintain a skill or function that was never learned or

acquired and is due to a disabling condition

Coverage of Habilitative Services

• Subject to permissible terms, conditions, exclusions and limitations, health

benefit plans, when required to provide essential health benefits, shall provide

coverage for physical, occupational and speech therapies, developmental

services and durable medical equipment for developmental delay,

developmental disability, developmental speech or language disorder,

developmental coordination disorder and mixed developmental disorder.



Arkansas Habilitative Services

Establishing Parity

• QHPs must offer habilitative services at parity with rehabilitative services.

Because developmental services are generally less expensive and required

on a long-term basis, the department has determined that parity must be

established through the use of unit equivalency. All medical QHPs must

include developmental services with unit limits at an acceptable level of parity

with Outpatient and Inpatient Rehabilitation for the 2015 plan year policies.

The minimum acceptable limits are included in the table below:


Rehabilitation

(OT, PT, ST)

Habilitative Services

(OT, PT, ST)

Habilitative

Developmental

Services

Outpatient

30 visits

(1 visit = 1 unit = 1

hour or less)

30 visits

(1 visit = 1 unit = 1hour or

less)

N/A

Inpatient 60 days N/A 180 units (1 unit = 1 hour)


Mandated Offerings as EHBs

• Due to Arkansas statutory language and the CCIIO requirement that

riders are not allowed with any filing, TMJ and Hearing Aids will be

considered Mandated Benefits and must be embedded in all QHPs,

unless the plan is an HMO not subject to the AR mandatory hearing aid

offering requirement (Bulletin 7-A 2009)

In-vitro Fertilization

• In-vitro is a mandated AR benefit so must be embedded in all QHPs

(except HMOs) even though it is not included in the state benchmark

plan



New AR-Mandated Benefits

• AR mandated benefits enacted after December 2011 are

considered in addition to EHB and must be excluded from the

silver EHB-only plan and excluded from premium allocated

towards EHBs in the actuarial memorandum. Act 1226 of 2013

enacted a new mandated benefit for Craniofacial surgery.

• These additional laws were enacted in 2013 and apply to existing

mandated benefits:

• Act 1259 of 2013: Mammography reimbursements

• Act 342 of 2013: Physical therapists must be paid the same as

general practice doctors

• Act 464 of 2013: Must have review process for excluded services

that are experimental

• Act 1233 of 2013: Revised coverage for orthotics


Essential Health Benefits: Cost Sharing

Maximum Out of Pocket Limits*

• Note that OON Emergency Services can count towards in-

network MOOP

* Based on Final 2015 Benefit and Payment Parameters


Medical Dental

Individual $6,600 $350

Family $13,200 $700

QHP Quality Requirements

Three Quality Goals:

• #1 - Inform Plan Certification – Includes QHP certification

standards, issuer quality improvement practices, and safety

• #2 - Provide Information to Consumers for Plan Selection –

Includes quality rating system and enrollee satisfaction surveys

• #3 - Monitor Plan Quality - Oversight and monitoring to include

complaints and appeals data, disenrollment information, and denied

claims


QHP Quality RequirementsGoal #1 - Inform Plan Certification – Includes QHP certification standards,

issuer quality improvement practices, and safety

Areas with current federal guidelines:

• Accreditation

• Patient Safety (may be more in the future)

Areas pending guidelines:

• Submission of Plan Performance

• Pediatric quality reporting measure

• Quality improvement strategy

While there is not yet federal guidance in some of these areas, QHP issuers are

required to participate in the AR Payment Improvement Initiative as a current

QHP certification standard, including the AR Patient-Centered Medical Home

Model in alignment with Medicaid PCMH standards.QHP Advisory Committee

30

QHP Quality RequirementsGoal #2 - Provide Information to Consumers for Plan Selection


• Proposed Quality Rating System Guidelines

• Proposed Enrollee Satisfaction Surveys

AID gathered input from stakeholders via the PMAC quality

subgroup and submitted comments on the initial QRS proposed rule.

Additional details regarding the rating methodologies were published

recently and can be found here (CMS Health Insurance Marketplace

Quality Initiatives website).


https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/QualityInitiativesGenInfo/Health-Insurance-Marketplace-Quality-Initiatives.html

QHP Quality RequirementsGoal #3 - Monitor Plan Quality


• Review of complaints and appeals as part of Accreditation requirements

Areas pending guidelines:

• Submission of disenrollment information and denied claims

AID conducts quarterly audits of Qualified Health Plans and quality

components will be included in the audits. QHP issuers are required

to submit requested data to AID in the oversight and monitoring

process.


Additional Updates

Third Party Payment of QHP Premiums

• CMS has published an interim final rule in 45 CFR §156.1250

regarding acceptance of certain third party payments. Issuers are

required to accept premiums from Ryan White HIV/AIDS

programs, Indian tribal organizations, and State and federal

government programs (such as the HCIP program)


Additional Updates

AID Bulletin 8-2013 regarding Marketing Standards

• QHP Issuers are prohibited from using a design of a program, entity

name, webpage, or internet solicitation intended to look like

Healthcare.gov, ARHealthconnector.org or Access Arkansas; nor shall a

person or entity create any name, logo, symbol, or web address of any

kind which is similar enough to mislead a consumer to believe it is a

direct pathway for purchase of qualified health plans offered in

Healthcare.gov, ARHealthconnector.org or Access Arkansas.

• QHP Marketing materials must be submitted to AID prior to use.


Z L

73 = 73% A/V Silver Variation



L= Limited Cost Sharing Variation

Z= Zero Cost Sharing Variation35

Z = Zero Cost Sharing Variation

L = Limited Cost Sharing Variation

CatastrophicStandard

Bronze

Standard

Silver

Standard

Gold

Z L Z L Z L

8773 9494

What about HCIP? Standard

Platinum

Plan Variations

Z

Catastrophic and Standard Plans

The Catastrophic Plan:

• Has an actuarial value of < 60%

• Is not required to have a Zero or Limited Cost Sharing Variation

The “Standard” Plans:

• Have actuarial values of 60%, 70%, and 80%, and 90% for

Bronze, Silver, and Gold and Platinum, respectively.

• Must include at least one Silver and one Gold plan for each

issuer.

36

Zero Cost Sharing Variation

The Zero Cost Sharing Variation:

• Is required for the Bronze, Silver, and Gold Plans

• Is for the purpose of removing all cost sharing for EHB

services for Indians up to 300% FPL.

• Must have zero cost sharing for both in and out of network

services.

• Is not offered in SHOP.

• Is used in the HCIP for individuals 0-100% FPL in plan

year 2014. Out of network cost sharing is not allowed in

the HCIP.37

Limited Cost Sharing Variation

The Limited Cost Sharing Variation:

• Is required for the Bronze, Silver, and Gold Plans

• Is for the purpose of removing cost sharing for EHB

services furnished by Indian Providers for Indians

regardless of income (over 300% FPL since below 300%

FPL will be covered by the Zero Cost Sharing variation).

• Looks just like the corresponding Bronze, Silver, and Gold

standard plan in the templates.

• Is not offered in SHOP.

38

Silver Plan Variations Part I

The Silver Plan Variations:

• Reduce cost sharing and MOOP amounts for

individuals up to 250% FPL.

• Must first increase actuarial value by reducing

MOOP, then increase actuarial value by reducing

cost sharing (copays and coinsurance).

• Are allowed to have out of network cost sharing.

• Must have equivalent non-EHB cost-sharing to

the corresponding standard silver plan.

• Are not offered in SHOP.

39




Silver Plan Variations Part II

The Silver Plan Variations are determined

according to income. Lower income individuals

qualify for higher cost sharing reduction plans

with higher A/V.

40




(a.k.a. “High Silver”)

94%87%

73%150% FPL

200% FPL

250% FPL

Silver Plan Variations Part III - MOOP

The Maximum Out of Pocket (MOOP) amounts

are required to be reduced for silver plan

variations. CCIIO may change these reduction

amount requirements over time.

41




(a.k.a. “High Silver”)

94%87%

73%150% FPL

200% FPL

250% FPL

The MOOP allowance for the standard silver

plan is $6,600 (2015). The MOOP reduced

allowances for 2015 are shown above

(tentative).

$2244$3300

$3300

HCIP Variations Part I

• HCIP uses Silver plan variations only.

• For plan year 2014, the plans used for

HCIP include the Zero Cost Sharing plan

and the 94% High Silver plan.

• The Zero Cost Sharing plan is not allowed

to have Out of Network cost sharing.

• The 94% High Silver Plan is given

specific cost sharing requirements (

Appendix E in the plan year 2015 QHP

Bulletin).

• The 94% high silver plan is allowed to

have OON cost sharing and was not

modified for the HCIP.

42






HCIP Variations Part II

• The variations that apply to HCIP are shown

below. The Actuarial Value is shown below

each of the “steps” and the applicable income

level by percent FPL is shown above each of

the steps. The silver plan variation with a 94%

A/V is shared between the HCIP program and

FFM.

43






100%94%

87%73%

151-200%

201-250% FPL

0-100% FPL

Zero Cost Sharing Plan (Z2)

HCIP FFM

94% Actuarial Value Plan

HCIP Variations Part III

Issuers submit separate benefit summaries

for plan variations, including HCIP variations.

The form requirements include:

• Limited Cost Sharing Plan Variation

• HCIP Zero Cost Sharing Plan (matches the

Marketplace plan other than potential

differences in title)

• Zero Cost Sharing Plan for Indians up to 300%

FPL

• 73% A/V Cost Sharing Variation








Plan Variation Naming Conventions

Naming Conventions:

Naming conventions will be required for plan schedules of

benefits:

Schedules should be named in the following way:

Sch- + [-Component Plan ID-] + [Variation ID]

For example: Sch-15234AR0070003-01


Summary of Plan Variations

46

• Zero Cost Sharing Variation: removes all cost sharing for EHB

services for Indians up to 300% FPL; must have zero cost sharing

for both in and out of network services.

• Limited Cost Sharing Variation: removes cost sharing for EHB

services furnished by Indian Providers for Indians regardless of

income.

• Silver Plan Variations: 73%, 87%, 94%. Reduce cost sharing

and MOOP amounts for individuals up to 250% FPL; are allowed

to have out of network cost sharing.

• Plans Used for HCIP:

• Zero Cost Sharing

• 94% Silver Variation

HCIP 94% A/V ("High-Silver") Cost Sharing


• The AID Bulletin includes the

required HCIP cost-sharing

options for high-silver 94%

A/V plans.

• Additional guidance with

specific cost-sharing guidance

is expected prior to May 1st.

The guidelines are expected

to align with benefits in the

templates.

• The cost-sharing

requirements are similar to

last year, with the exception of

the removal of the emergency

copay.

Rate Filing

Filing for Actuarial Rate Review:

• The process will be similar to last year; issuers submit the

actuarial memorandum and rates will be reviewed for all

QHPs (except SADPs)

• Carriers need to ensure that actuaries are available for

questions and discussions during the QHP review period

and can respond within 48 hours


Rate Filing

Issuers must submit all required rate review documentation, including:


Part I - Unified Rate

Review (URR) Template

Rate Review Template developed by

HHS. The updated template can be found

here.

Part II Consumer

Justification Narrative-

Justification information

received for rate

increase, if applicable.

Justification narrative for rate increases

(that exceed 10% threshold)

Part III Actuarial

Memorandum

Rate filing documentation to support QHP

rates and all rate increases. A

supplemental actuarial variation

spreadsheet form required for AR rate

reviews can be found in Attachment L.

http://www.serff.com/documents/plan_management_data_templates_unified.xlsm

Rate Filing

Additional rate filing updates:

• Rate increases over 10% are required to be filed in HIOS. CMS

has indicated that rate increases must be filed and approved by

the state in the HIOS system before the rates can be shown

correctly on Healthcare.gov.

• A field to indicate premium allocation towards EHBs has been

added in the proposed benefits and cost-sharing template. This

must be completed and must align with information in the

actuarial memorandum.


Review Tools

• Issuers will have access to the QHP Application Review Tools this

year and we recommend issuers take advantage of these tools

for a smooth certification process

• These tools are a method for reviewing against specific standards

such as the 30% threshold for ECPs, annual limitation on cost

sharing, catastrophic plan requirements, etc.

• The Data Integrity Tool (DIT) is specifically designed for issuers to

(1) provide a method for issuers to check that the data contained

in their templates is in the correct format; and (2) provide issuers

with feedback immediately and reduce resubmissions


Overview of QHP Application Review Tools

Select Market Reform

Standards

Marketplace-Specific

Standards

• Actuarial Value

• Annual limitation on

Cost Sharing (i.e. EHB

out-of-pocket

maximum)

• Catastrophic Plan

Requirements

• EHB Discriminatory

Benefit Design

• Formulary-USP

Category Class Count

• Non-discrimination

Formulary Outlier

• Non-discrimination

Formulary Clinical

Appropriateness

• Accreditation

• Cost Sharing Reduction

Plan Variation

Requirements

• Essential Community

Providers

• Meaningful Difference

• Program Attestation

• Service Area

• SHOP tying provision

• Non-discrimination Cost

Sharing Outlier


Questions?


Attachment Index

A. 2015 Final Letter to Issuers

B. SERFF Filing Instructions

C. Arkansas Health Plan Submission Requirements

D. QHP Checklist and AR Essential Health Benefits Guidelines

E. USPSTF preventive health benefits guide

F. USPSTF Tobacco Cessation Recommendations

G. Network Adequacy Checklist

H. State benchmark plans

• Medical-BCBS Health Advantage POS

• Mental Health and Substance Use Disorder-QCA FEHBP

• Pediatric Vision-CHIP (AR Kids B)

• Pediatric Dental-CHIP (AR Kids B)

I. Benchmark drug formulary


http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact=8&ved=0CCsQFjAA&url=http%3A%2F%2Fwww.cms.gov%2FCCIIO%2FResources%2FRegulations-and-Guidance%2FDownloads%2F2015-final-issuer-letter-3-14-2014.pdf&ei=SlZNU6eVJoiy8AHxpIAo&usg=AFQjCNE8XsYVg5NgN97s2MwB_OXnYCM1wQ&sig2=mpFSFHonxaGxmaXIQbNOsw&bvm=bv.64764171,d.b2U

http://www.uspreventiveservicestaskforce.org/uspstf/uspsabrecs.htm

http://www.uspreventiveservicestaskforce.org/uspstf09/tobacco/tobaccosum2.htm

http://hbe.arkansas.gov/FFE/Plan/BCBS-POS-SmGrp.pdf

http://hbe.arkansas.gov/FFE/Plan/QC-Federal-EHBP.pdf

http://hbe.arkansas.gov/FFE/Plan/PediatricVision.pdf

http://hbe.arkansas.gov/FFE/Plan/PediatricDental.pdf

Attachment Index

…continued

J. URRT and Instructions

K. Uniform Certificate of Authority Application “UCAA”.

L. AR Actuarial Memorandum Form

M. Uniform Modification Recertification Form

N. AID QHP Bulletin 9-2014


http://www.serff.com/documents/plan_management_data_templates_unified.xlsm

http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact=8&ved=0CCsQFjAA&url=http://www.serff.com/documents/plan_management_data_templates_help_partI_unified_rate_review.pdf&ei=R09NU9LbE7O38gHCg4GwDQ&usg=AFQjCNE4nJLYZucE8Ozn3fVeVpcaeDAi0Q&sig2=oiVIIFqoOr8dq_N7T4MGQw&bvm=bv.64764171,d.b2U

http://www.naic.org/industry_ucaa.htm

http://insurance.arkansas.gov/legal/Bulletins/9-2014.pdf

56

Public Consulting Group, Inc.

148 State Street, Tenth Floor, Boston, Massachusetts 02109

(617) 426-2026, www.publicconsultinggroup.com

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