• December 01, 2015  |  By

    No QHPs Comparable to CHIP, Says (Delayed) HHS Certification

  • Like many others that watch child health policy closely, we have been anxiously awaiting release of the months-overdue Congressionally-mandated study comparing CHIP with coverage children receive through qualified health plans (QHPs) in the marketplaces.

    Released just before Thanksgiving, the HHS certification summary reinforces what growing evidence has indicated: No QHPs were found comparable to CHIP. Not one. And this makes sense – we know CHIP was designed solely for kids, while marketplace plans were largely built with adults, the majority of those in need of coverage, in mind. Plus, CHIP includes stronger cost-sharing protections that, by definition, mean families would end up paying more for QHPs even with the ACA’s financial help.

    The certification analysis looked at the second lowest cost silver plan (SLCSP) in the largest rating area in a state compared to the state’s CHIP plan, finding that “the average out-of-pocket spending in the SLCSP was higher than out-of-pocket spending in CHIP for CHIP-eligible children in all states reviewed.” It also finds “…benefits packages in CHIP are generally more comprehensive for “child-specific” services (such as dental, vision, and habilitation services) and for children with special health care needs as compared to those offered by QHPs.”

    The table beginning on page 4 summarizes information on 1) actuarial value – or the percentage of costs paid by the QHP or CHIP – and 2) the combined out-of-pocket cost for families of cost sharing plus any required premiums. In every state, CHIP is more affordable for families.

    The most helpful paragraph in the document is worth repeating here:

    Accordingly, and based on this review, the Secretary is not certifying any QHPs as comparable to CHIP coverage at this time. Because the allotments provided under section 2104 of the Act are sufficient to provide coverage to all children who are eligible to be targeted low-income children at this time and in the foreseeable future, the requirement at 2105(d)(3)(B) of the Act that requires states to establish processes to enroll children in certified QHPs does not apply.

    We are thrilled to finally see this report, but as researchers were dismayed by its sparseness. The ACA requirement for this study, passed in 2010, provided enough lead time to uncover much more information about exactly what children receive in a range of scenarios. More detail – even when the ultimate outcome is the same – would help us all to identify the exact service gaps and areas where marketplaces need to be improved to better serve kids, CHIP-eligible or not. Some additional questions we had include:

    1. What do we know about kids with different levels of income and how they may fare? How does this vary by state?
    1. What do we know about kids with special health care needs or chronic conditions and how their utilization of benefits or out-of-pocket costs compared to relatively healthy kids? Our 2014 study of hypothetical children in Arizona found that while most every family would pay more for QHP coverage for their children, they would pay many times more for children with chronic health care needs in QHPs compared to CHIP.
    1. What about benefits that a plan does not cover? They would not show up in AV calculation – which only includes cost-sharing for covered services. But paying for additional, necessary services would further affect a family’s out-of-pocket costs. How much? And what are the service gaps?

    So, while the study’s conclusion is helpful we were left wanting more. As we look to the future of children’s coverage the debate about where and how children should be covered will be considered again as we move closer to 2017. A more thorough examination of these research questions by HHS, which brings unique resources to bear to the issue, would have enriched the debate.

    Check out the certification summary here.

    Elisabeth Wright Burak
    is the Senior Program Director at the Center for Children and Families