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The ACA, Round 2: How to Stay Out of Trouble

With the next open-enrollment period for health benefits just around the corner, there are some important things to do now.

As we approach year two of open enrollment for the Affordable Care Act's health-benefit exchanges, the intense public glare of 2013 on the online exchanges may have dimmed, but the operational pressures on the 15 state-based exchanges and the federal marketplace are every bit as great as they were last year. Marketplace teams are working feverishly, mostly out of public view, to help ensure that this year's enrollment proceeds without the massive problems encountered last year.

Here are five things that exchange executives should be doing now to help achieve that goal.

1. Communicate with the public and manage expectations:

One of the biggest challenges of year one was the inability on the part of many marketplace leaders to manage the public's expectations. Promises were made that users would enjoy a "Travelocity-like" experience, with only tepid warnings that there might be "some hiccups." The reality was that many consumers experienced something far short of a modern online transaction, encountering problems that certainly exceeded anyone's definition of a hiccup. Exchange leaders should communicate openly and honestly with the public to advertise changes and enhancements while making clear that the marketplaces are still works in progress and that it will take time before dot-com-like shopping experiences are the uniform standard.

2. Test, test, test:

A central lesson learned from year one was the indispensable importance of testing. Many of the problems encountered at the start of the 2013 open-enrollment period can be traced to the fact that the exchanges were launched even as the software-development lifecycle was in mid-stream. Time needed for testing was cut in order to meet ambitious deadlines. There is no substitute for proper testing, so it's better to at least consider removing problematic functionalities until they're ready for prime time rather than shortchanging the testing process.

3. Perform operational-readiness reviews as though it was year one all over again:

Although they've had a year to work out the kinks, marketplace leaders should still prepare for the worst -- even if they are optimistic and expect the best when the flood of enrollees arrives. This means running operational-readiness reviews that test not just the technology but also the non-technical aspects of marketplace operations. This includes refreshing training for brokers and navigators, ensuring that call centers are ready to handle the expected volume, and testing manual processes to ensure they work. Backup plans should be ready and tested in the event that something goes wrong.

4. Fast-track two to three innovations that will enhance the consumer experience:

Even in states where the launch went well last year (think Connecticut or Kentucky), the shopping experience was still, for the most part, pretty basic. But we learned that the public was far more willing to be patient with a functioning exchange, even if it lacked advanced features, than one with all the bells and whistles that did not work. It is likely, however, that public expectations will be higher in year two (see No. 1 above). Marketplaces should consider releasing a few innovations to address those expectations and to trumpet them as evidence that the shopping experience is improving. These might include enhanced Web-based search-and-compare capabilities or mobile applications.

5. Keep some attention focused on the January deadline to start mailing IRS forms:

All eyes may be on Nov. 15 right now, but it would be a mistake to overlook the next big deadline: the initial mailing in January of IRS Form 1095 to people who have purchased plans via the marketplaces. These new forms are complicated (nearly three dozen fields in three form parts) and require back-end reconciliations between exchanges and plan issuers to get the information right. As of now, there are serious questions about the readiness of marketplaces to meet this deadline. As one marketplace CEO recently told me, the Form 1095s could be October 2013 all over again.

Let's hope not. Nobody involved with implementing the health law wants to re-live the traumas that afflicted so many aspects of last year's launch. The time to keep another scenario like that one from unfolding this time around is right now.

The views expressed here are the author's alone and do not represent those of KPMG.

Paul Hencoski is KPMG LLP’s national lead partner for government health and human services.
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