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This is actually a pretty good one. The fines are enough that it will hurt them enough to get it right.
The much larger issue for consumers is that when they ask a doctor's office if they take UHC, the office can say 'Yes' even though they may only take a commercial, group plan and have nothing to do with an ACA or MAPD plan-consumers
Maybe for MAPD, but $100 for ACA isn't even going to move the needle at all...
12.30.2015
This administration's ignorance of how the real world operates never abates. Today, Sylvia Burwell says that 3 out of 5 existing insureds picked a different plan for 2016, because they're ENTHUSIASTIC about Obamacare. (And she was sober!)
Everyone else in America realizes that the real reason for 3 out of 5 choosing a different plan for 2016, is because Obamacare forced health insurers to make policy changes that made existing 2015 plans too expensive, too impractical, or simply impossible to keep.
Anyone have the official guidance? How they define the fine is very important.
I can't find it the official rule, but news reports I see say "per beneficiary", "per violation", and some say "per day". I presume "beneficiary" means "primary or dependent enrolled on a plan that uses the network in question", as that is how they define it for other reports (like the Medicaid Spending Per Beneficiary report).
200k enrolled, 100 errors out of 40,000 providers in your system, $100 fine per beneficiary/violation comes out to two billion dollars a day. Might be $2B per year if the "per day" claim is wrong. Might be only $20M if it's not per violation, and it might be significantly lower if it's only "per complaint" or "per contract".
No matter what, this isn't going to be a $100/day slap on the wrist until their directory is accurate. It's going to be a whole lot more.
If you're like BlueCross where 25%+ of your directory is inaccurate, and you have millions enrolled, a week worth of fines will shut you down...
Appears they will be amending 45 C.F.R. 156.805(a) to include network inaccuracy.
"(c) Maximum penalty. The maximum amount of penalty imposed for each violation is $100 for each day for each QHP issuer for each individual adversely affected by the QHP issuer's non-compliance;" implies it is per-individual on a plan with inaccurate network data.