NY

Document ID: CMS-2012-0141-0008
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: December 05 2012, at 12:00 AM Eastern Standard Time
Date Posted: December 28 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: November 26 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: December 26 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 1jw-82d7-nar5
View Document:  View as format xml

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There has to be parity between Exchange and non-Exchange product. Therefore commissions, minimum participation requirements, etc have to be equal between all products. Additionally, merging small group and individual markets creates an unknown and unquantifiable situation. By definition, the Exchange is adding uninsured to the marketplace who are individuals with no history. Merging the pools prior to having credible experience for these people could cause rates in subsequent years to increase dramatically if carriers make incorrect assumptions about the claims experience. It's best to hold off on this until 2017 when more information is available.

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