CHA submitted joint comments on behalf of allied children’s groups, and joined with the Habilitation Coalition in response to a Request for Information
(RFI) that asked for recommendations on how to eliminate barriers to insurers’ ability to sell health insurance across state lines. The RFI from the Centers for Medicare & Medicaid Services sought input on ways to encourage states to form Health Care Choice Compacts as authorized under Section 1333 of the Affordable Care Act (ACA). Section 1333 allows the sale of qualified health plans in two or more states that have entered into a compact. The two joint comment letters focused on the need for strong regulatory guardrails to prevent the potential weakening of benefits, the challenges of developing comprehensive provider networks across state lines that include providers for all covered benefits, and the lack of clarity regarding regulatory oversight and accountability of plan coverage.