NHeLP Comments on California Health Benefit Exchange

1. What minimum standards for qualified health plans in the Exchange would ensure a basic level of service, access, consumer protection and health care quality?

The state of California has developed extensive rules governing health plans through the Knox-­?Keene Act. At a minimum, the Exchange should allow only Knox-­?Keene licensed plans to participate in the Exchange as QHPs to ensure that all enrollees have access to the consumer protection provisions of the Knox-­?Keene Act. The Exchange is authorized by 45 C.F.R. § 156.200 to require and monitory plan licensing and standing. By requiring QHPs to be Knox-­?Keene licensed, the Exchange will ensure that QHP enrollees have access to the consumer remedies available through the Department of Managed Health Care in addition to exercising their grievance rights through the Exchange or the QHPs themselves. In the alternative, if the Exchange decides to permit plans that are not Knox-­? Keene-­?licensed to become certified as QHPs, the Exchange must require, through the contracting process, those plans to provide Knox-­?Keene protections to enrollees.