Considerations for product governance risk management

A key focus of the insurance regulatory authorities around the world has been the protection of policyholder interest. This has resulted in more emphasis on product governance and product life-cycle management. The insurance directive launched under the European Union insurance law has issued guidelines for insurers to embed product oversight and governance into their risk management frameworks.

A robust product governance process can help reduce mis-selling and complaints, and increase policyholder confidence in the market. It can also ensure internal and regulatory compliance for the products offered by the insurer.

The core components of a robust product governance process are:

• Product governance policy
• Product development
• Pricing and value
• Distribution and sales
• Legal, compliance and risk management
• Ongoing assessment of the product

To read more about building a strong product governance policy, read Neha Taneja’s article here.

Critical Point podcast: “Healthcare waste and how to find it”

Milliman’s new podcast, Critical Point, presents unique perspectives from the firm’s professionals. The podcast’s debut episode, “Healthcare waste and how to find it,” features Jackie Sehr, Marcos Dachary, and Dr. David Mirkin from Milliman MedInsight®, a data warehousing and healthcare analytics platform. In this episode, they discuss healthcare waste and approaches to minimize waste and reduce unnecessary costs across the American healthcare system.

To listen to this episode of Critical Point, click here.

Regulatory roundup

More healthcare-related regulatory news for plan sponsors, including links to detailed information.

2018 Social Security and Medicare Trustees Reports released
The Social Security and Medicare Boards of Trustees issued their annual financial review of the programs. The projections indicate that income is sufficient to pay full scheduled benefits until 2026 for Medicare’s Hospital Insurance program, until 2032 for Social Security’s Disability Insurance program, and until 2034 for Social Security’s Old Age and Survivors Insurance program. The Supplementary Medical Insurance (SMI) Trust Fund remains adequately financed throughout the projection period, but only because SMI has unlimited access to general revenues.

For more information, click here.

The CMS RDS Center changes its location for retiree and cost report files
The Retiree Drug Subsidy (RDS) Center of the Centers for Medicare and Medicaid Services (CMS) is changing the location where retiree and cost report files are sent via Connect:Direct. By the end of 2018, all files that are currently sent to the RDS Center via Connect:Direct must be sent to the new location. This change only impacts vendors that submit data to the RDS Center via Connect:Direct and does not affect vendors that submit data using the RDS secure website.

For more information, click here.

Commercial health insurance: Overview of 2016 financial results and emerging enrollment and premium data

In this report, Milliman’s Paul Houchens, Jason Clarkson, and Jason Melek provide a detailed review of the commercial health insurance industry’s financial results in 2016 and evaluate changes in the market’s expense structure and enrollment prior to relative years. They also provide enrollment and Advanced Premium Tax Credits estimates for 2017.

Medicaid managed care market penetration quadruples over past decade

Milliman has announced the availability of its annual research into the financial results and administrative expenses associated with Medicaid managed care plans. This year’s report marks the 10th edition of Milliman’s research, and combines the financial and administrative analysis into one comprehensive report, including an in-depth examination of Medicaid managed care plans’ medical loss ratios (MLRs), administrative loss ratios (ALRs), underwriting ratios (UW ratios), and risk-based capital (RBC) ratios. The information is of significant value to the Medicaid industry as enrollment and revenue continue to increase year-over-year.

Observing the changes that have occurred in the Medicaid managed care landscape over the last 10 years provides valuable insight into the makeup of the market. We have made enhancements to this year’s report that help to highlight the growth in this industry and the ebb and flow of experience over time.

Key findings from the analysis include:

• The average underwriting gain of 0.9% in calendar year (CY) 2017 remained relatively stable from the composite gains observed in CY 2016
• During the past 10 years of our analysis, the data studied for the report has seen a 250% growth in membership and over 400% growth in revenue for the studied Medicaid managed care programs
• Administrative expenses continue to increase on a per member per month (PMPM) basis, but decrease as a percentage of revenue has been observed from CY 2016 to CY 2017

To see the Medicaid administrative expenses report, click here.

Managing autism treatment in self-funded plans

Self-funded plans frequently deal with issues at the intersection of physical health, behavioral health, medical science, and government regulation. One emerging issue that relates to each of these areas is Applied Behavior Analysis (ABA) treatment for autism spectrum disorders (ASD).

ABA is one of the fastest growing state benefit mandates. Today, 46 states mandate some form of autism coverage with varying degrees of benefit coverage and limits. ABA is a prime example of the type of coverage required by state mandates.

The prevalence of ASD has risen precipitously. In the early 1980s, population prevalence was estimated at 0.05% (five of 10,000 children). The most recent studies estimate prevalence to be 1.5% (one in 68 children). Traditionally, commercial insurers excluded or minimally covered treatment for ASD. However, more recent federal mental health parity laws and essential health benefit requirements (EHBs) of the Patient Protection and Affordable Care Act (ACA) have served to increase access to ASD treatments.

ABA is a behavioral strategy to improve socially significant behaviors to a meaningful degree. Targeted behaviors include adaptive living skills such as gross/fine motor skills, social skills, communication, reading, eating, and dressing. The ABA treatment regimen typically involves highly structured, intensive interventions for up to 30 or 40 hours per week. The course of treatment can last many years, from diagnosis at early ages (e.g., ages 3 to 4) through adolescence (and sometimes beyond).

While self-funded employer-sponsored plans are not required to comply with state mandates under federal law (ERISA), they are not immune from the trend toward greater ABA coverage driven by state mandates for insured plans.

Challenges for self-insured plan sponsors include:

Medical necessity. Medical carriers will often advise that ABA is not medically necessary for its self-insured customers but will cover it for its insured business to meet state mandate requirements. This makes it difficult for plan sponsors to explain to members why it is not covered under their plan.
Cost. Assuming conservatively the average age of diagnosis is 4 years and average age of completion is 15 years, adding this benefit can be a long-term expense to the plan. Cost estimates range between $25,000 and $50,000 per case per year.
Utilization management. If plan sponsors decide to cover ABA, then it is important to make sure members access school-/community-based services, which play a significant and progressive role in offsetting plan costs.
Network management and provider credentialing. As demand for ABA services grows, plan sponsors may want to review credentialing and network utilization to assure ongoing access to qualified providers for these services.
Compliance. Plan sponsors must not run afoul of the Mental Health Parity and Addiction Equity Act (MHPAEA), which prohibits plans from restricting mental health benefits more so than physical health benefits.
Related benefits. Even if a plan specifically excludes coverage for ASD treatment and diagnosis, members with autism are most likely already receiving related functional health benefits such as physical therapy and speech therapy (habilitative and rehabilitative). It is important to understand the interconnectedness of benefit administration and the underlying equities.

The increasing prevalence of ASD, the growth in state ASD benefit mandates, and the widespread treatment of ASD through ABA can affect self-funded plan sponsors, requiring them to think comprehensively about balancing member needs and access with care cost and care management.

This article first appeared on LaborPress.org.