Joint allied children’s and habilitation group comments on 2023 Exchange rule

We joined with allied children’s organizations and the Habilitation Coalition to submit comment letters on the proposed Notice of Benefit and Payment Parameters for 2023 (NBPP), which establishes requirements for Exchange coverage for the 2023 plan year. The annual rule also has implications for the broader private insurance market. The 2023 NBPP continues this administration’s rollback and revision of certain policies from the Trump administration to strengthen coverage requirements. 

Both letters generally support the proposed rule but call for the administration to further strengthen the essential health benefits and network adequacy standards to ensure enrollees have timely access to the services they need. The allied children’s group letter also calls on the administration to rescind rules that extended the availability of non ACA-compliant plans, including short-term limited duration and association health plans, and health care sharing ministries.