NO to the Exchange
Bad public policy and unsustainable Poses financial risk to states to ensure self-sustainability Still have incomplete guidance and regulations - final rule contains over 90 references to future rulemaking
Medicaid has largely remained structurally unchanged since signed into law by President Johnson in 1965.
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Unsustainable
Louisiana has not accepted federal dollars to act as federal agent to create the exchange.
No ongoing funding for state exchange operations after 2015, so states must absorb those costs, which are now undeterminable due to the lack of federal guidance.
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No Clear Guidance
Initial rules insufficient for planning purposes and non-existent for the federally facilitated exchanges Guidance not final, but states still expected to have operational exchanges by January 1, 2013 No Essential Benefits Package regulations - no sign when they will be finished Even with guidance, impossible to create a staterun exchange within that federal timeline that complies with existing state procurement processes.
6
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Federally-facilitated Exchange
No regulations exist for the FFE, so our knowledge is limited:
FFE will/may determine eligibility for qualified health plans, tax credits, cost sharing reductions, and Medicaid and CHIP eligibility based on Modified Adjusted Gross Income (MAGI) with some state decisions. FFE will provide eligibility information to the applicable State agency to enroll those individuals in coverage under the traditional Medicaid eligibility criteria.
7
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January 1, 2013 is seen as the deadline for the Essential Benefits Package regulation, though HHS is aiming to finish sooner. Impacts insurance providers attempting to design their products and policies in time to receive HHSs approval for the Exchanges.
8
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10
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