Late today, FAH submitted comments to CMS Administrator Seema Verma on the Notice of Benefit and Payment Parameters for 2019 Proposed Rule (2019 Exchange Rule). The rule proposes modifications to the regulations governing the Exchange created by the Affordable Care Act.
FAH believes that an important goal of the ACA – and implemented through the Exchange – is to provide a consumer-friendly opportunity to shop for and compare health insurance products that offer meaningful coverage at an affordable price.
Unfortunately, many of the changes proposed in the 2019 Exchange Rule go against those principles and could lead to higher cost, lower value and reduced benefit adequacy.
Key provisions in the proposed rule of particular interest to hospitals are unfavorable changes to how Essential Health Benefits (EHBs) are determined, further weakening of the current network adequacy standards, reduction of the MLR and rate review requirements and the adoption of policies that make the Marketplaces less consumer-friendly.
In comments, the FAH echoes previous positions, including the support for comprehensive EHBs, the need for CMS to strengthen the Exchange’s network adequacy provisions in order to ensure access to provider services, and support for a robust MLR and rate review policy.
You can read the comment letter here.