• Letter or Testimony
  • January 6, 2021

Children's Groups' Joint Comments on Annual Private Insurance Rule

Five national children’s organizations joined with CHA in comments to CMS on the 2022 proposed Notice of Benefit and Payment Parameters (NBPP), which sets standards for qualified health plans sold through the Exchanges and has implications for the broader private insurance market. Our letter emphasizes our opposition to proposals that we believe could impede seamless access to appropriate coverage and care for children, particularly those with serious, chronic or complex conditions, and pregnant women. In particular, 

  • The rule allows all states to use private web brokers, agents and insurers to enroll people in individual insurance plans, which we believe will result in loss of coverage or the steering of families to inadequate coverage. 
  • The rule changes Section 1332 waiver statutory guardrails, which could expose children, pregnant women and families to higher costs and less access to critically needed services. 
  • The rule continues flexibilities afforded to states and insurers in 2018 regarding the selection of essential health benefit benchmark plans, which could leave children without the age-appropriate benefits they need and their families with higher out-of-pocket costs. 

The American Academy of Pediatrics, Children’s Defense Fund, Family Voices, First Focus on Children, and the National Association of Pediatric Nurse Practitioners joined with CHA on the comment letter.