SERFF Filings Down, PPACA Implementation and Slow Economy Blamed

August 30, 2012 at 08:50 AM
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Usage of SERFF, (System for Electronic Rate and Form Filing), a system that states in partnership with the industry have developed to automate the rate and form filing process, has been under budget by 16,000 transactions through June due to the effect of the Patient Protection and Affordable Care Act (PPACA) as well as the economy, according to NAIC notes.

SERFF reported 558,689 total filings in 2011, down from 565,475 in 2010. Since 2008, there have been at least half a million filings per year. Filings have crested more than 100-fold since the program was launched in 2001.

The new numbers reflect filings earlier this year, despite licensing 88 companies in 2012. More than 3,500 unique companies are currently licensed.

SERFF Board member and New Hampshire Insurance Commissioner Roger A. Sevigny indicated that health companies are holding filings in anticipation of health care reform, according to the NAIC Executive Committee minutes taken during the NAIC Meeting in Atlanta earlier this month.

SERFF also held a Health Insurance Exchange Plan Management Forum Aug. 9 with attendance by approximately 250 state regulators, industry, and staff from the Center for Consumer Information and Insurance Oversight (CCIIO). Forty-seven jurisdictions were represented.

One participant said regulatory agencies and insurance providers have only one point of consensus about SERFF and the exchanges: "We are all scared spit-less." as National Underwriter reported from Atlanta

SERFF cannot work on creating a federal-state database until the Department of Health and Human Services publishes final rules. The major medical health rate filings will be public, unlike other SERFF filings, under the national health reform law.

SERFF will only help facilitate sharing of information and will not dictate what kinds of information states and the federal government transmit.

In addition, several companies have indicated that they are not developing new products due to the "sluggish economy," the New Hampshire commissioner said.

SERFF is ramping up to be the back end system for rate and form filings under PPACA.

Fritz said SERFF will only help facilitate sharing of information and will not dictate what kinds of information states and the federal government transmit.

SERFF released the first of several releases that will include Plan Management functionality on July 12. The Essential Health Benefits (EHB) configuration for purposes of compliance with the PPACA,was added in this release, as well as a specific General Instructions area for Plan Management documents and instructions from states to carriers.

The next iteration, SERFF v 6.0, is expected to be released in December, according to Sevigny. This release will include the Plan Management functionality needed to allow issuers to submit qualified health plans (QHPs) for inclusion on the health care exchanges.

In order for industry health filers to correctly report PPACA-related filings to the states, SERFF has implemented three field values — SERFF requires that at least one of these field values be selected in order to submit a PPACA-eligible filing, its website stated

PPACA-eligible filings will include a new Submission Requirement – the PPACA Uniform Compliance Summary. This uniform document will assist industry in ensuring they are meeting the immediate market reform requirements and will assist states in expediting the review of PPACA filings.

According to the SERFF site, 49 states, the District of Columbia, Puerto Rico and over 3,400 insurance companies, third-party filers, rating organizations and other companies are committed to SERFF.

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