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Board to study 'not-to-exceed' rate language after last-minute CMS Part D announcement
Summary
Board members and staff discussed building procedural flexibility (for example, 'not to exceed' rate language) so staff can implement late federal announcements without convening special meetings; staff emphasized Moda must enroll in the CMS demonstration immediately and promised to explore structural options for future board seasons.
Agency staff told the board that the late July CMS announcement required a special meeting because CMS set a same-day signup deadline for its voluntary Part D demonstration. "We thought it was more appropriate for the board to hear this and authorize the premiums before Moda officially signed up for the demonstration on behalf of the contract," Dave said, noting the agency had a very short timeline to act.
Board and staff discussion turned to whether future resolution language could give the agency limited flexibility in late-summer cases, such as a 'not to exceed' rate cap that would allow staff to lower rates if new federal information arrives before open enrollment. Dave said staff will consider the concept over the next board season and bring structural language for the board’s consideration.
The board asked staff to draft clear written communications to members explaining both the price change and Moda’s role in enrolling in the CMS demonstration. No formal policy change was adopted at this meeting; staff were directed to study options and return to the board with proposals.
