Thursday, March 14, 2013


TO: Health Carriers Writing Business in the State of Iowa
FROM: Commissioner Nick Gerhart
DATE: March 13, 2013
RE: Geographic Rating Area and other Information
The Patient Protection and Affordable Care Act of 2010 (“ACA”) provides the authority for states to create their own
marketplace or to utilize a federally facilitated exchange. The State of Iowa elected to participate in a state/federal
partnership to conduct the Plan Management (“PM”) function. The blueprint outlining this intention was submitted on
February 14, 2013. On March 7, 2013, CMS conditionally approved Iowa’s blueprint for a state/federal partnership
exchange. This purpose of this memorandum is to update health insurance carriers (“issuers”) licensed to do business in the State of Iowa on specific items.
PM includes, but is not limited to, the development and implementation of processes and standards for certification of
qualified health plans (“QHP’s”) offered in the Iowa health benefit exchange (“Exchange”). The Iowa Insurance Division (“Division”) will conduct QHP certification review for compliance with federal law and standards and state laws and standards. This includes:
● Licensure and in good standing;
● Service area;
● Network adequacy;
● Essential community providers;
● Marketing oversight;
● Accreditation;
● Essential health benefit (“EHB”) standards;
● Actuarial value standards;
● Discriminatory benefit design;
● Benefits for meaningful difference;
● Rates (including new and increases).
Effective January 1, 2014 the Exchange will offer issuers a state-wide marketplace to make it easier for individuals and small employers to compare and purchase health insurance. Individuals will begin the enrollment process October 1, 2013.
New regulations are published weekly. With final regulations more clarity is provided. 45 C.F.R. 147.102 provides that
states may determine their own rating area. If a state does not elect to define its rating area, the default shall be one rating area for each metropolitan statistical area in the state and one rating area compromising all non-metropolitan statistical areas in the state, as defined by the Office of Management Budget.
With this memorandum we are proposing the geographic rating area in the attached exhibit. This rating area divides the State of Iowa into six areas for geographic rating and is divided between counties. The Division will accept written
comments on this proposed rating area through March 18, 2013. You may email your comments to Becky Blum at
Additionally, the Division will hold a meeting for anyone interested in discussing this proposed rating area on March 19, 2013, from 8:30 am – 10:00 am at the Iowa Insurance Division office at 330 Maple Street. A short comment period is necessitated by the fact that Iowa’s selection must be communicated to CMS by March 29, 2013.
The Division is also attaching a proposed timeline for guidance to Issuers. This timeline will be fluid and may change
from today, but is offered as guidance. It is believed the Division will begin accepting QHP applications in April. The
Division understands that the QHP application will be done on March 28, 2013, and SERFF will be ready to accept filings in April. The Division will solicit requests for letters of intent to participate in the near future. The Division will give review priority to QHP’s filed for the Exchange. The Division must have all QHP’s to CCIIO prior to July 31, 2013. As part of our rate review process the Division will engage with outside consultants. The costs of this review will be billed to the Issuers.
Issuers are also reminded of the need to obtain their HIOS identification number [].
Issuers in Iowa will file QHP’s through both HIOS and SERFF. In addition to obtaining a HIOS number Issuers need to
review the model templates [ ] and the draft Annual Letter to Issuers on Federally-facilitated and State Partnership Exchanges [].
See Attachments for List of Counties and Area Map