Illinois State Partnership Exchange Blueprint Application
On Friday November 16th, the state of Illinois submitted its Blueprint Application to the federal Department of Health and Human Services (HHS). This application will be reviewed by HHS for approval, allowing the state to proceed in partnership with the federal government to operate Illinois’ health insurance Exchange beginning on January 1, 2014.
The Blueprint Application is an evolving document. As the partnership progresses and the state of Illinois continues to work towards a state-based Exchange, the document will be adjusted and expanded. However, it will remain a procedural document that is meant to detail workflow within and between agencies of state government. The full Blueprint Application is available here.
In a state partnership, Illinois had the opportunity to apply to operate some of the plan management and consumer assistance functions of the Exchange, leaving the remaining functions to be operated by the federal government. The Blueprint Application is a technical document that lays out how the state will coordinate with the federal government in the first year of the Exchange and how the state internally will carry out its plan management and consumer assistance responsibilities under the partnership. HHS will use this document as evidence that Illinois can meet its obligation for operating the plan management and consumer assistance functions.
The plan management portion of the Blueprint Application details the process the Illinois Department of Insurance (DOI) will undertake to recommend Qualified Health Plans (QHPs) for certification to HHS. The state was required to detail components related to plan management, including:
- The transition process for individuals currently in the Illinois Pre-Existing Condition Insurance Plan (IPXP). These individuals will transition to coverage through the Exchange on January 1, 2014.
- DOI’s process to recommend QHPs for federal certification according to requirements detailed in federal regulations. This includes describing how DOI will ensure that issuers and health plans meet each of the QHP certification standards, the process DOI will use to evaluate issuers and health plans against each of the QHP certification standards, and any differences specific to stand-alone dental plans and the Small Business Health Options Program (SHOP). It also includes a description of the state entities responsible for QHP review, including a description of roles and responsibilities of each entity as they relate to QHP certification standards, and a description of the integration between the Federally-facilitated Exchange and DOI.
- DOI’s process for reviewing licensure, solvency, product pricing, rating variation, plan rating, rate review, third-party accreditation, service area and network adequacy, essential health benefits, marketing standards, non-discrimination standards, quality standards, transparency reporting, multi-state plans, and several other criteria.
- DOI’s capacity to ensure QHPs’ ongoing compliance with QHP certification requirements and the ability to recertify, decertify, and manage the appeal of decertification determinations.
Plan management functions required for QHP review and recommendation are similar to the typical regulatory responsibilities of the Department. The Affordable Care Act requires new areas of review, but the state will leverage the processes and workflows that are already established and in use within DOI and the Department of Public Health.
The consumer assistance portion of the Blueprint Application details the process DOI will undertake to administer the In-Person Assistance (IPA) functions of the Exchange, as well as the oversight functions for the Navigator program in Illinois. The state was required to detail components related to consumer assistance, including:
- Describing a process to support and oversee aspects of the Federally-facilitated Exchange Navigator program, including ensuring that Navigators are adhering to the training and conflict of interest standards established by the Federally-facilitated Exchange and to the privacy and security standards developed by the Federally-facilitated Exchange.
- Describing the in-person assistance program, distinct from the Navigator program, including a process to operate the program consistent with Federally-facilitated Exchange guidance, policies, and procedures. Illinois plans to operate the IPA program with goals similar to the Navigator program: to help consumers access the expanded subsidized health insurance coverage programs and reformed and re-organized insurance markets that will result from the Affordable Care Act. The IPA program will act as a supplement to the Navigator program and will not serve redundant purposes or populations. To distinguish the IPA program, Illinois will ensure that entities contracted through the program serve populations geographically and demographically distinct from the Navigator program.
DOI is well-prepared to take on administrative duties, with experience overseeing similar programs, including the Senior Health Insurance Program (SHIP) and producer licensing, as well as experience in providing direct assistance to consumers through the Office of Consumer Health Insurance (OCHI).
Privacy, Security and Oversight
The partnership model also requires the state to perform privacy, security and oversight functions. The Blueprint Application details the process the Department of Insurance will undertake to administer these cross-cutting functions, including:
- Describing the written policies and procedures regarding the privacy and security standards.
- The process for maintaining an accurate accounting and analysis of all activities, receipts, and expenditures, and providing periodic reports in relation to the activities undertaken by the Exchange to HHS as required, including enrollment statistics, consumer satisfaction reports, relevant audit reports and any required state and federal reporting.
- Describing the contractual, outsourcing, and partnership agreements with vendors and/or state and federal agencies for all Exchange activities and functionality as needed, including data and privacy agreements.