Manatt Healthcare Professionals Comment on Lessons Learned from Part D Implementation

Manatt Healthcare Professionals Comment on Lessons Learned from Part D Implementation

"Part D Startup in '06 Offers Implementation Lessons for Upcoming Debut of Exchanges"
AIS's Health Reform Week

October 1, 2012 - Health Reform Week interviewed Manatt healthcare partner Wendy Krasner, as well as Joel Ario, a managing director with Manatt Health Solutions, for insight into how the lessons learned from Medicare's implementation of Part D can be applied to the startup of health insurance exchanges.

As reported by Health Reform Week, tens of millions of Americans are expected to begin signing up for health insurance exchanges in October 2013, eight years after enrollment began for Medicare's Part D prescription drug program. Industry experts told the publication that there are lessons to be learned from Part D implementation, which may be useful in the startup of exchanges.

Ario said that a basic lesson learned from Part D is that carriers ought to strive to be involved up front in the rollout of exchanges. "If carriers didn't get into the initial [Part D] rollout, I think many regretted that," said Ario. "It is important with these new programs to get in on the ground floor and build membership."

To help with such carrier involvement from the beginning, Ario said state-based exchanges for the most part will be open marketplaces that allow health plans to participate if they meet minimum standards. "States are lining up this way," he said, citing as an example Maryland's switch from its decision in 2010 to be an "open purchaser" for its exchange to its determination in 2011 to use an open marketplace for it.

Krasner recalled that one of the initial concerns with Part D was about how many plans would participate. Centers for Medicare & Medicaid Services, at the beginning, decided to use a model allowing all qualified plans and subsequently made a significant effort to limit the numbers of plans and choices in order to strike a proper balance. Many people think exchanges should take the same approach, letting everyone in and then narrowing the field, noted Krasner.

Limiting plans up front may make consumer choices easier, and one could argue that either approach has tradeoffs, she said, but up-front limits may lead to contentiousness and litigation by nonparticipants. "I think plans will worry if they're not in there on day one [with respect to exchanges], they're not in there at all," said Krasner.

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