When's it due? Who knows?

In 2012, several key deadlines and decision points in federal healthcare policymaking will have significant impacts on providers. But some of those deadlines remain a mystery.

One important as-yet-undetermined 2012 date is the deadline for states to provide the information proving they will have operational insurance exchanges as required by the Patient Protection and Affordable Care Act.

It is widely known that on Jan. 1, 2013, HHS will pronounce which states appear likely to begin enrollment in their insurance marketplaces by Oct. 1 of that year.

But when are the applications from the states—on which HHS will base its decisions—due to HHS? So far, there are no due dates. Obviously, states cannot submit their complex exchange plans on Jan. 1 and expect judgments on their viability that same day, but HHS has not yet established how many days, weeks or months earlier those plans are due, according to an HHS official.

A July 15 proposed rule on the state exchanges delineated many of the requirements for such “exchange plans," but not their due dates.

“The Exchange Plan will be submitted through a procedure to be described in additional guidance,” stated the proposed rule.

Such dates are critical, not only for the states facing judgment, but also for providers who are preparing to work with health plans from either a state exchange or from an as-yet-undefined federal version that will operate in their place. So far, 10 states have publically indicated their intention to not establish their own exchanges but it remains unclear whether any of the rest will complete the process in time to launch exchanges in 2014. So early indications—like the number of exchange plans submitted—will be closely watched.

The insurance marketplaces are a central pillar of the 2010 law and the vehicles through which at least 16 million people are expected to gain coverage.

Follow Rich Daly on Twitter @MHRDaly.



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