June 2015


OR Advisory Committee Recommends Embedding in Standard Exchange Plans
In a meeting this month, Oregon’s Essential Health Benefits/Standard Plan Rule-making Advisory Committee voted 6 to 4 to recommend the Insurance Division embed pediatric dental benefits in standard plan designs offered on the Exchange in Plan Year 2017.

If this recommendation is upheld by the DOI, Oregon would join Connecticut in requiring medical carriers to embed pediatric dental benefits in standard plan designs. Thus, medical carriers would be required to offer a standard benefit plan with embedded dental in order to participate on the Exchange. Medical carriers could also offer additional non-standard plans, which are allowed to omit the dental benefits. The concern from an SADP perspective is that if QHP issuers are required to embed in at least one plan, they may only offer that one plan or embed in all other Exchange offerings (standard and non) thus limiting consumer choice and the market for standalone products.

Matt Sinnott with Willamette and a volunteer on the Exchange Policy Workgroup (EPW) attended the meeting and reported several votes changed throughout the Committee’s discussion. Two agent/broker representatives were the primary proponents of embedding in the standard plan designs and hoped embedding in standard plans will be a sort of tipping point for the spread of embedding across the individual and small group markets. Arguments referenced risk spreading, premium impacts and the possibility of resolving reasonable assurance confusion if medical carriers offered embedded plans more widely.

Wakley consultants and the DOI reminded the workgroup that premium is only one part of the cost equation and other cost-sharing elements should be considered. This was supported by Matt’s testimony with background from NADP’s Infographic, “Dental Benefits Choices for Children, One Size Does Not Fit All.” A medical carrier also responded during the meeting that it’s unlikely they would make all their portfolio decisions based on three standard plans required for participation on the Exchange.  

The critical details on how the dental benefits would be standardized remain unsettled and will ultimately fall on the shoulders of the DOI, who can reject the recommendation or accept it and consider several implementation challenges:

If the standard plan applies the pediatric dental benefits to the full medical deductible, then the health premium impact of adding those benefits could be nominal. However, this would expose consumers to substantial cost sharing challenges when getting dental services (e.g. a $2,000 deductible instead of $50 for dental). On the other hand, if they choose not to apply the pediatric dental to the deductible (i.e. include a separate dental deductible as in the DC Exchange), then the Committee’s original argument regarding health premium impact is less valid, and they will have to set standardization parameters at the DOI level. The DOI will also be challenged to implement this in a manner that aligns with the federal rules. The Committee talked about having two sets of standard plans, with pediatric dental embedded and without, because they are undecided on how this decision would impact the QHP issuers freedom with regards to pediatric dental inside and outside of the Exchange.

NADP with the EPW and member plans in the state will monitor the situation and provide comments if allowed.

OR EHB Rulemaking Advisory Committee webpage: 
Wakley Consulting Group Presentation to OR EHB Committee: 



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