Exchange Contracting – the Significant Risk to Providers Posed by the Federal Grace Period
The ABA Health Law Section's Payment and Reimbursement Interest Group is pleased to present, "Exchange Contracting – the Significant Risk to Providers Posed by the Federal Grace Period." The speaker is C. Brett Johnson, JD, MPH, MS, Associate Director, Center for Medical and Regulatory Policy, California Medical Association.
In 2014, many providers of healthcare services may not only discover that they are now contracted for health benefit exchange products under existing contracts, but that they may also be holding risk under one or more of those contracts. This is because federal law will allow exchange plan issuers to pend claims submitted by providers in the last two months of a federally subsidized patient’s three-month grace period for premium payment delinquency. If the patient is terminated from the QHP at the end of the three months for an unpaid premium balance, then the plan issuer can deny all claims submitted on that patient in those last two months. Questions abound, however, as to the extent this federal provision preempts state laws on matters such as prompt payment and rescissions.
If you have any questions or concerns, please contact Simeon Carson, Associate Director, at email@example.com.