• Letter or Testimony
  • December 1, 2017

Joint Comment Letters on 2019 Draft Exchange/Commercial Plan Guidance

CHA spearheaded a joint comment letter from eight allied children’s groups on the 2019 Draft Notice of Benefit and Payment Parameters (NBPP) and also joined with disability advocacy groups and other safety net providers on separate joint comment letters. The NBPP establishes the standards for Exchange and other commercial plans for 2019. 

Joint children’s group comments: 

  • Urge CMS to reconsider its proposed revisions to the essential health benefits (EHBs), which could leave children worse off and their families with higher out-of-pocket costs.
  • Oppose the delegation to states and accrediting entities of regulatory oversight of provider networks in Exchanges plans.
  • Oppose reductions in the minimum threshold for inclusion of essential community providers (ECPs) in networks. 

Habilitation Coalition comments express serious concerns regarding the impact of proposed changes to the EHBs on access to habilitation services and devices for children and adults with disabilities. 

ECP Coalition comments ask CMS to reinstate the 30 percent minimum threshold for ECP participation in plan networks.