As enacted in the Patient Protection and Affordable Care Act ("ACA"), states are required to have established operational health benefit exchanges by January 1, 2014, or the federal government will implement one for them. These exchanges will allow individuals and small businesses to buy health care coverage and are expected to add approximately 30 million currently uninsured persons to the health insurance market. Most of the health plans that will be offered on such exchanges will be managed care plans with networks of participating providers. Thus, the resulting new business will be covered by hospital, physician, and other provider participation agreements with such managed care plans.
Hospitals, physicians, and other providers of health care services should start reviewing their commercial managed care participation agreements to determine whether they will apply to exchange products when they are implemented, especially if the term of the agreement is evergreen or ends after January 1, 2014. Enrollment in exchange products begins in October 2013, but health plans will likely submit their applications to offer products on these exchanges, including a listing of their provider networks for such exchange products, beginning in early 2013. Therefore, health plans need to know which providers will be participating in those networks by early 2013.
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