1332 Waiver Task Force

1332 Task Force Update

April 2017 1332 Powerpoint Presentation


Roger Flippo




The 1332 Innovation Waiver Task Force convened Tuesday, April 18th, 2017 at 1:30pm at the Oklahoma Hospital Association Seminar room with most stakeholders present.


Federal Updates – Julie Cox-Kain, Deputy Secretary of Health and Human Services

Ms Kain gave us an overview of the most recent federal developments that will impact our individual marketplace in 2018. They are as follows:

  • 2018 Annual Open Enrollment Period to start on Nov 1, 2017 and run through December 15, 2017.
  • Increased Special Enrollment Verification will increase from 50% to 100% in all states using the Healthcare.gov platform
  • Payment of Past Due Premiums may be required by carriers of individuals before enrolling into a plan with same issuer the following year
  • Actuarial Value Flexibility allows issuers additional actuarial value flexibility within the metal tier system to develop more choices with lower premium options for consumers
  • Network Adequacy reduces waste of taxpayer dollars by eliminating duplicative review of network adequacy by the federal government, returning oversight of network adequacy to the states that are best positioned to evaluate network adequacy.


Reinsurance and High Risk Pools – Julie Cox -Kain and Buffy Heater

The task force is recommending our initial 1332 Innovation Waiver application focus on reinsurance and high risk pool options to quickly stabilize the market so that participating carrier’s financial risks are mitigated and Oklahomans can continue to use their tax credits to purchase coverage on healthcare.gov. Three options are being considered. They are as follows:

  • Reinsurance – insurance carriers are paid part of a high-cost and/or high-need individual’s claims over a specified amount. Individuals remain in the total pool. e.g. Alaska, Minnesota
  • High Risk Pool – high-cost individuals are offered coverage in a separate pool potentially lowering the cost for those remaining in the market. e.g. Wisconsin
  • Hybrid – is combination of cost-based and condition-based high risk reimbursement options. Cost-based – rather than setting up a separate high-risk pool, one approach is to use funds to reimburse health plans a portion of the claims costs of their high cost enrollees. e.g. Minnnesota; High cost individuals would remain in the private individual market. States establish the definition of “high-cost’ as an attachment point and claims cap. Condition – based – As an alternative, reimbursements could be based on an enrollee having one or more specified high-risk conditions. e.g. Alaska or Arizona

Implementation Considerations for Oklahoma:

  • Need authorizing legislation and 1332 waiver approval
  • Need upfront funding, via an insurance plan assessment
  • Need to identify administering entity and infrastructure
  • The federal government will reimburse a majority of the costs via pass through funding
  • The remaining state funds necessary will be a portion of the total funding
  • Timing and coordination of multiple activities occurring simultaneously

Preliminary Impact Assessment of Concept Paper Strategies – Erik Krisle – Austin Bordelon – Leavitt Partners

Results of Impact Analysis:

  • High-Risk Pool or Reinsurance Program – Introducing new stability funding – whether through a reinsurance program or high-risk pool – has the ability to directly reduce the underlying cost of a risk pool and, in turn, lower premiums and slow cost growth. Directly subsidizing the individual market risk pool has an immediate effect on premiums for the state. Based on the subsidy amount, premiums are estimated to drop 5% (50 M), 11% (100 M), and 22% (200 M). Individual market enrollment could increase between 1.5% to 3% under $50M of stability funding for the state or 6.2% to 11.2% with $200M of new funding. As premiums are reduced, savings to the federal government from lower subsidy payments are realized and may be eligible to be collected for future program funding.
  • Effects of Moving to a Wider Age Band – Allowing greater variance to the age bands for underwriting insurance may support greater participation among younger age, lower risk, Oklahomans. Widening the age band is likely to reduce premiums for young enrollees and increase them for older populations. A 5:1 age band could reduce young adult premiums as much as 29% and increase them by 21% for older enrollees. Lower premiums are likely to encourage new enrollment among younger populations while “pricing out” a subset of the older population.
  • Standardizing Subsidies Based on Age and Income – With the goal of providing additional support to younger populations and moving to a subsidy structure that also places more downward pressure on premiums, the State will evaluate calculating insurance subsidies based on age and income. On Exchange Market enrollment with standardized subsidy based on age and Income is forecasted to result in a 6,000 to 14,000 increase over baseline in enrollment for the 2019 enrollment period.
  • Reallocating Subsidies for 0-300% FPL Population – With a significant population lacking coverage below the Federal Poverty Line (FPL), Oklahoma would also like to evaluate the effects of moving eligibility for premium assistance down to 0-300% FPL (adjusting from 100-400% FPL today). As a potential way to cover the Medicaid “gap population”, we considered the effects of lowering subsidy eligibility below 100% and two possible methods for subsidy calculation. Concerns of Medicaid cannibalization warranted a second scenario with higher member cost-sharing. Scenario # 1 – ACA subsidy shifted downward. Scenario #2 – ACA subsidy swapped from upper end. Enrollment increases are projected to be between 26,500 and 98,500 in 2019 depending on the scenario. Cost projections are an increase of $150 – $499 million depending on the scenario.

Timeline and Next Steps – Julie Cox-Kain, Buffy Heater

  • Conduct legislative review mid-April
  • Continue impact analysis assessment by consultants, engagement of federal officials and stakeholders, report at June Task Force meeting
  • Monitor federal developments regarding ACA amendments, CSR decision
  • Secure actuarial consultant, proceed with waiver development
  • Schedule tribal consultation and public comment periods
  • Monitor progress on authorizing legislation and funding
  • Pursue rate and form review responsibilities and infrastructure
  • Goal is to have waiver approval by January 1, 2018.

Next Meeting: June 20, 2017

Feb 21, 2017 Meeting
1:30pm – 3:00pm
Oklahoma State Capitol

Roger Flippo
OSAHU President

The 1332 Waiver Task Force met at the Oklahoma Hospital Association Conference room. After a welcome from Deputy Secretary of Health and Human Services, Julie Cox-Kain, Kevin Jessop of Evolve gave a brief summary of the initial results of the Business and Consumer Surveys. Read Entire Meeting Summary

View Meeting PDF Presentation

1332 Task Force concept paper was released Dec 30, 2016

Roger Flippo
December 28, 2016

Take the Survey

Business is the key to our state’s success. This survey is designed to collect information about Oklahoma business’ and employers’ perspectives on health insurance and wellness programs as they relate to workforce costs, productivity, and returning value on your business investment. How does the health of the Oklahoma workforce and your employees affect your business? What impact does access or the lack of access to healthcare have on your bottom line? What barriers and challenges do you face when it comes to providing health and wellness benefits to your employees?

As we continue work on the Oklahoma Health Improvement Plan (Healthy Oklahoma 2020) and health and wellness-related workforce policy in the state, we are interested in learning what employers need to facilitate growth and business success, and how we can partner together to develop strategies for improving workforce readiness and productivity in our state.

This survey should take you approximately 10 minutes to complete. As you are asked to provide specific information, please feel free to estimate. A number of questions have a menu of options to make it easy to select an answer and move through the survey quickly. We know your time is valuable. This is an anonymous survey, and your personal details will not be attached to specific answers.

Take the Survey


Thank you for your help!

  • Governor Mary Fallin
  • Oklahoma State Department of Health
  • Oklahoma Department of Commerce
  • State Chamber of Oklahoma Research Foundation
  • Insure Oklahoma
  • Oklahoma Employment Security Commission
  • Oklahoma Office of Workforce Development
  • Oklahoma Association of Health Underwriters

Roger Flippo
Sept 26, 2016

The second meeting of the 1332 State Innovation Task Force convened on September 26, 2016 in the Office of the Governor, Large Conference Room at the State Capitol in Oklahoma City. All major stakeholders were in attendance representing business, brokers, providers, payers, Indian Tribes, and government entities. A presentation was given by HHH staff in accordance with the meeting agenda. Full President’s Summary

1332 Meeting 9 26 Final
Consumer CSC 9 26 16
Global Health 1332 Data Responses
BCBS The Health of America Report
BCBSOK 1332 Data Responses