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You are here: www.tdi.texas.gov . health . fhrcarriers

Affordable Care Act Resources for Health Carriers

TDI Resources | Federal Resources | Filing Time Frames

TDI Resources

  • Bulletin on Department approach to form and rate review in anticipation of changes to federal law that became effective on January 1, 2014, and geographic rating areas for Texas under federal law
  • Product Checklists for compliance with Texas requirements
  • The Affordable Care Act Resource Page provides general information designed for a broad audience and includes details on the essential health benefits package in Texas
  • Frequently Asked Questions (FAQs) - updated May 4, 2016

Federal Resources

  • Federal regulations and guidance are organized by topic on the Center for Information and Insurance Oversight CCIIO resource page
  • The NAIC has compiled a resource document that includes FAQs released by the U.S. Department of Health and Human Services (HHS) and the U.S. Department of Labor (DOL)

CMS Regulatory Role in Texas

CMS is responsible for the enforcement of the PPACA market reforms (Public Health Service Act (PHSA) sections 2723 and 2761) and for the review of rate increases above the reasonableness review threshold (PHSA section 2794).

In order to enforce the provisions above, CMS requires Texas carriers to submit form filings through HIOS for federal review; see CCIIO's February 5, 2016, letter to Texas issuers RE: 2016 Form Filing Instructions and Health Insurance Oversight System (HIOS) Technical Assistance for Plan Year 2017.

Geographic Rating Areas for Texas Issuers

Federal regulations established 26 geographic rating areas for Texas: one for each of the 25 Metropolitan Statistical Areas (MSAs) located in Texas, and one additional geographic rating area that applies to all areas of the state not part of an MSA; see federal guidance, "Texas geographic rating areas, including specific geographic divisions for the Individual and Small Group market."

Guidance for Qualified Health Plans (QHPs) Participating in the Federally Facilitated Marketplace

CMS' primary source of operational and technical guidance are the FINAL 2017 Letter to Issuers in the Federally-facilitated Marketplaces and the HHS Notice of Benefit and Payment Parameters for 2017. Carriers may also access technical assistance via www.regtap.info, email the Help Desk at CMS_FEPS@cms.hhs.gov, or call 1-855-CMS-1515.

Filing Time Frames

The table below illustrates the deadlines for filing rates and forms for plans that will be effective on or after January 1, 2017, including those that will be sold in the health insurance marketplace (exchange), with open enrollment beginning November 1, 2016.

Deadlines for Filing Rates and Forms for Plans
Filing Type State Federal
Exchange (QHP) Forms PPO: 60 days prior to use /
HMO: 30 days prior to use 1
May 11, 2016
Exchange (QHP) Rates File and use 1 May 11, 2016
Non-exchange Forms PPO: 60 days prior to use /
HMO: 30 days prior to use 1
60 days prior to use 2
Non-exchange Rates File and use 1 60 days prior to use 2, 3
  1. Texas does not impose different filing requirements for exchange products; however, carriers may need to file simultaneously with TDI and HHS to meet exchange deadlines.
  2. Federal guidance indicates that all carriers utilizing open enrollment periods may have to adhere to the full federal open enrollment periods. Thus, even issuers not seeking to sell on the exchange should consider whether they must offer guaranteed issue coverage beginning November 1, 2016, for 2017 effective dates or whether they will have to offer coverage all year round.
  3. Federal guidance indicates that if an issuer has any QHPs in the single risk pool, all rate filings (even for non-QHPs) must be submitted by the QHP filing deadline. The non-exchange rate filing deadline applies only for issuers with no QHPs in the single risk pool.


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Last updated: 06/17/2016

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