Indiana Health Insurance Enforcement and Consumer Protections Grant Award

Cycle I Grant Application Summary

Indiana Grantee: Indiana Department of Insurance

Award Date: October 31, 2016

Total Award: $1,297,729.08

Baseline Award: $476,998

Selected Market Reforms Amount: $600,000

Workload Award Amount: $220,731.08

• Section 2707- The Indiana Department of Insurance will develop a discriminatory benefit design checklist to identify benefit designs that discriminate due to health status, age, disease state or any other factor prohibited by law. Areas of focus will include benefits included in the benchmark plan, state mandates, blanket exclusions, parity in mental health/substance use disorder and medical/surgical benefits, and all other information deemed pertinent by the Department of Insurance. Indiana will also continue to enhance its Formulary Review Tool including the efficacy of covered drugs listed in the Category and Class Template, composition of drug tiers, and compliance of covered drugs with current medical authority for the disease the drugs treat. Implementing these updates will enhance enforcement by verifying issuers are not using discriminatory practices in selecting covered drugs and ensuring issuer compliance with Federal and State laws and sub-regulatory guidance.

• Section 2713 - The Indiana Department of Insurance will create consumer outreach programs to educate consumers about basic information about insurance issues related to disease states, preventive services covered at zero cost-sharing related to disease states, and contact information should a consumer need additional information or have questions. Indiana will also explore the creation and implementation of a new interactive voice response system for consumers, which would consist of an automated recording that contains a menu of topics that will play when a consumer calls the Consumer Services Division hotline. The recording would contain a list of topics the consumer can select, including, for example, “ACA Information.” Once a consumer has selected this topic, a second recording containing a menu of topics pertaining only to ACA plans will play. Such topics could include services covered at zero cost-sharing, appeals information, balance billing, premium tax credit/cost sharing reductions and 1095A Forms, and consumer complaint processes.

• Section 2718 - The Indiana Department of Insurance will develop internal tools to review policy form language, template data, and Medical Loss Ratio (MLR) data submitted by health insurance issuers. Indiana plans to implement a MLR review program. Under this program, health insurance issuers issuing non-grandfathered, Affordable Care Act (ACA) compliant plans would submit their MLR annual reporting form to the Department of Insurance and the department will compare the data listed on the issuers' MLR annual reporting form to the data listed on the Supplemental Health Care Exhibits. This program would improve consumer protection and enforcement by ensuring health insurance issuers are reporting the correct amount of rebates and accurately and timely distributing rebates, if required.

• Section 2719 - The Indiana Department of Insurance will create a consumer outreach program to develop consumer information about internal and external appeals processes. Consumer information would be distributed in print and available on Indiana’s website. Indiana will upgrade its tracking and coding systems to ensure better data integrity and improve market analysis. Additionally, the Department of Insurance will review prior authorizations and analyze appeal determinations issued by independent review organizations certified by the Indiana Department of Insurance. Both types of review will enhance enforcement by verifying the accuracy and fairness in appeals determinations as well as improve market analysis by increasing the Department of Insurance’s ability to identify and rectify problems.

• Section 2726 - The Indiana Department of Insurance will develop and implement checklists to use for policy form language review to review for parity in mental health/substance use disorder and medical/surgical benefits. Areas of focus will include quantitative treatment limits, non-quantitative treatment limits, amounts for deductibles, copays and coinsurance, requirements for prior authorization and step therapy. Indiana will also upgrade its current Mental Health Parity and Addiction Equity Act (MHPAEA) Template to an automated process to facilitate a more uniform and comprehensive review of forms. The Department of Insurance will also coordinate meetings with other State agencies and special interest groups to identify barriers to insurance coverage for mental health and substance use disorders, collaborate to create solutions for such barriers, identify future issues and find proactive measures to prevent future issues.