On August 3, CMS released at its REGTAP.info website (registration required), a series of frequently asked questions (FAQs), most of which provide additional detail on the transparency and quality rating guidelines released on July 25, 2016. The FAQs clarify that only qualified health plan insurers in consumer display pilot states (Michigan, Ohio, Oregon, Pennsylvania, Virginia, and Wisconsin) and in states with state-based marketplaces that display star ratings can use their star ratings in marketing materials. CMS will issue disclaimer language for insurers to use that will caution consumers that the display of the star-rating system is still being consumer tested.
The FAQs also clarify a point about the claims and appeals data that QHP and standalone dental plan insurers must submit under the transparency initiative in federally facilitated marketplace states and in state-based marketplace states that use the FFM enrollment platform: these data are for claims and appeals for services provided in 2015, not for services provided earlier for which a claim was processed in 2015. Insurers that are new to the marketplace for 2017 must complete the transparency template, including URLs for claims payment and other policies, but do not have to submit data since they would not have 2015 data. Initial transparency information must be submitted to September 2, 2016 and final data by September 23.
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