• Letter or Testimony
  • July 29, 2021

Joint children's and habilitation letters in support of strengthening Exchange requirements

We spearheaded a letter with allied children’s groups that expresses support for key policy changes included in a proposed rule governing Exchanges that will have positive implications for children’s health and health care. The rule repeals, rescinds and/or modifies certain regulatory requirements for Exchanges that were finalized under the prior administration. The joint letter expresses support for provisions that establish a special enrollment period for consumers with income up to 150 percent of the federal poverty level; require navigators to provide post-enrollment assistance, including information on how to use health coverage; repeal a state option to allow brokers and insurers to take over most Exchange functions; restore guardrails for state Section 1332 waivers that will ensure that waiver coverage is at least as comprehensive and affordable as coverage absent the waiver; and clarify that Exchange plans must comply with mental health parity requirements. We also recommend several ways to further strengthen the rule to ensure they meet the needs of families and children and urge the administration to issue rules to strengthen essential health benefits (EHBs) and pediatric network adequacy standards, and rescind rules that allowed for the expanded availability of short-term limited duration and other non ACA-compliant plans. We signed a similar letter with the Habilitation Coalition that highlights the importance of reinstating the Section 1332 guardrails, strengthening EHBs, and restricting non ACA-compliant plans to increase access to habilitation services and devices for children and adults.