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Overview of Proposed Exchange, Medicaid, and IRS Regulations

Manatt Health Solutions

Many details remain unclear on how California consumers and small businesses will obtain coverage under the Affordable Care Act. An analysis of draft federal regulations provides a look at what's ahead.

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September 2011

A Manatt Health Solutions report prepared for CHCF analyzes three draft federal regulations that, taken together, offer fresh insight into how consumers and small businesses will obtain health insurance across the continuum of coverage proposed in the Affordable Care Act (ACA).

Two of the proposed regulations, released by the US Department of Health and Human Services (HHS), address Medicaid and Children's Health Insurance Program (CHIP) eligibility and enrollment simplification; eligibility for health insurance exchanges, insurance affordability programs, and Qualified Health Plans; and standards for employee participation in Small Business Health Options (SHOP) exchanges. The third proposed regulation, issued by the Internal Revenue Service, provides guidance on determining eligibility for and calculating the amount of premium tax credits available through the exchange.

These proposed regulations, released on the heels of the latest round of the Exchange Establishment Grant awards (in which California was awarded nearly $40 million):

  • Provide a new level of operational detail that informs California's planning efforts
  • Guide the design and implementation of business processes, IT, and administrative systems
  • Will ultimately impact consumer experience with the California Health Benefit Exchange and Medi-Cal

The Manatt analysis provides an overview of the main provisions of the proposed rules and their implications for California implementation. The analysis builds on closely related work conducted by Manatt for a national audience through the Robert Wood Johnson Foundation. Both reports are available through the External Links below.