Web-based health insurance exchanges (HIE) (to be used by consumers to buy health insurance on-line) will have to reconcile lots of complicated enrollment and eligibility information using multiple insurer and government databases and, as a result, it's unlikely that they'll be up and running by the 2014 deadline. What's more, there doesn't appear to be anything in the proposed regulations to keep the Feds from intruding into the States' traditionally independent regulation of health insurance by unilaterally "delisting" any health insurer that fails to meet HHS' expectations. The DMCB suspects Uncle Sam can ultimately get away with that because Federal money is being used to subsidize the insurance premiums for low income individuals who use the HIEs.
But what about "disease management?" asks the DMCB. As it understands it, the Affordable Care Act only permits the listing of "qualified health plans" (QHPs) in state exchanges. The benefits and coverage levels that must be in place in order for an insurer to meet that "qualified" moniker is currently under development (and, by the way, attracting its own share of controversy ). The DMCB hopes that the Secretary of HHS will take advantage of the ACA's language that gives the Secretary of HHS latitude in setting "other benefits" in QHPs as an opportunity to include "disease" or "population health management" in the mix.
Even if the final regulations don't include disease management as a qualified benefit, that doesn't mean that the Feds or the States can't ask qualified health plans to also include consumer information on whether they offer disease management programs (along with the chronic conditions that are addressed) and what percent of their primary care network are covered by patient centered medical homes.
This is an opportune time to bring this up. While States and the Feds are scrambling to get the exchanges up and running, having two additional fields on line that describe the depth of care management coverage is a no brainer. Who could possibly disagree with the idea that consumers need information to better help them access high quality primary care and manage chronic conditions?