Under the Affordable Care Act (ACA), states are responsible for implementing a complex array of health reforms, most notably Health Insurance Exchanges, Medicaid expansion, and health insurance market regulations.  ACA presents states, particularly state Medicaid agencies and insurance departments, with unprecedented policy, fiscal, programmatic, operational, and systems challenges.

A helpful new policy brief from RWJF’s State Health Reform Assistance Network identifies the key milestones that states should reach by the close of 2012 if they hope to be ready for 2014, when Health Insurance Exchanges, Medicaid expansion, federally subsidized health coverage, individual and employer mandates, and a new regulatory framework for health insurance are set to begin.  State staff are well versed in ACA requirements, although federal rules remain fairly general and state Medicaid directors and insurance commissioners have many questions for the Centers for Medicare and Medicaid Services (CMS), particularly the CMS Center for Consumer Information and Insurance Oversight (CCIIO).  However, the brief will be quite helpful for legislators, health plans, provider groups, advocates, and news media needing more details on the massive undertaking that is ACA implementation..

The policy brief, State Milestones for ACA Implementation, provides a high-level framework for Health Insurance Exchange (HIX) development and implementation efforts, with milestones segmented under three major categories: Health Insurance Exchange, Private Insurance Market Reforms, and Medicaid Expansion. Milestones also identify core HIX functions for those states that depend on the “Federally Facilitated Exchange” (the euphemism for CMS-run HIX in any state unwilling or unable to establish a federally compliant HIX in time), as those states may choose to assume some of those functions. Individual milestones effect business operations, policy development, and IT system architecture.

With a goal to operationalize a state-based Exchange meeting federal certification requirements in January of 2013, the brief provides detailed milestones for exchange set-up, eligibility, enrollment, plan management, consumer assistance, financial management, SHOP-specific functions, system design, and vendor procurement.

The brief also details milestones for both the individual and small group markets, with a goal to implement ACA-mandated private insurance market reforms, make decisions around discretionary reforms in the individual and small group insurance markets, and define essential health benefits packages.

To prepare for ACA-mandated Medicaid expansion and modernized eligibility system implementation, the brief details milestones for eligibility, enrollment, benefits, program financing and funding, operations, system design, and vendor procurement.

To read or download the full policy brief, click here (PDF).  If you have specific questions about Exchanges or Medicaid expansion, please contact my colleagues at Sellers Dorsey.  The Sellers Dorsey team is currently advising clients, including states and health plans, on Health Insurance Exchange implementation, qualified health plan requirements, and Medicaid expansion issues.