CCIIO Posts Largest of Small Group Plans That Could Be Used for Benefits Requirement

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By Sara Hansard  

A document listing health plans that would likely qualify as benchmarks for benefits that many plans must cover in 2014 under the health care reform law was posted Jan. 25 by the Center for Consumer Information and Insurance Oversight.

The document, Essential Health Benefits: Illustrative List of the Largest Three Small Group Products by State, said it was providing “illustrative information” to complement a guidance bulletin CCIIO issued Dec. 16 (see previous article).

In the Dec. 16 guidance bulletin, the Department of Health and Human Services said it intends to allow states to choose one of four types of benchmark plans on which to base essential health benefits (EHBs) that would be required in each state:

• the plan with the largest number of enrollees in any of the three largest small group insurance products;

• any of the largest three state employee health benefit plans by enrollment;

• any of the largest three national Federal Employees Health Benefits Program (FEHBP) plan options by enrollment; or

• the largest insured commercial non-Medicaid health maintenance organization operating in the state.

Under the Patient Protection and Affordable Care Act, in 2014 “non-grandfathered” individual and small group market plans that were not in effect before PPACA was enacted in 2010 must cover the EHBs inside and outside of health insurance exchange markets that are to be in operation in all states. The EHBs must cover 10 benefit categories listed in the law, and the benefits package is to equal the scope of typical employer plans.

Largest Small Group Plans Listed

The Jan. 25 document posted on CCIIO's website lists the largest three small group health plans in each state, using June 30, 2011, enrollment data from, a website developed by HHS to help implement PPACA.

The Jan. 25 document also lists the top three nationally available FEHBP plans based on enrollment: the Blue Cross Blue Shield standard and basic option plans and the Government Employees Health Association standard option plan.

The document said the information was provided “to facilitate a better understanding of the intended approach to EHBs.” The document is “not an official list of products that will be benchmark options for state consideration,” nor does it “represent any endorsement by HHS of any particular products,” it said.

EHB Guidance Bulletin Criticized

Patient and consumer advocacy groups say they are unhappy with HHS's EHB guidance bulletin. They argue that PPACA calls for a national, comprehensive benefits standard, rather than allowing varying state standards that might not cover some needed services (see previous article).

HHS is still receiving public comments on the guidance bulletin, which are due Jan. 31, and the agency “will subsequently release regulations,” the Jan. 25 document said. HHS said that in the future it intends to provide additional information on enrollment details for each specific combination of benefits and cost-sharing requirements in the three largest small group plans in each state.

For More Information

Essential Health Benefits: Illustrative List of the Largest Three Small Group Products by State is available in HealthDocs™.