Children's Groups' Joint Comments on Proposed Rule on Short Term Limited Duration Plans

Children's Groups' Joint Comments on Proposed Rule on Short Term Limited Duration Plans

Children's Hospital Association leads children’s groups' comments on the proposed rule to limit Short Term Limited Duration Insurance.
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CHA spearheaded joint comments from allied children’s organizations on the proposed rule to limit the duration of Short-term, Limited Duration (STLDI) Plans from up to three years to four months. The letter supports the original intent of STLDI plans, which is to only fill short-term coverage gaps and not to serve as long-term insurance coverage.

A 2018 rule expanded the availability of STLDI plans, which contradicts the intent of these plans and increases the potential that families will choose a seemingly affordable, but not comprehensive, plan as their long-term coverage choice.

Most federal standards and rules that apply to individual health insurance, such as those under the ACA, the Health Insurance Portability and Accountability Act, the Mental Health Parity and Addiction Equity Act and the No Surprises Act, do not apply to short-term plans. This lack of fundamental protection leaves families at substantial financial and health risk when they enroll in a STLDI plan.

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