• Letter or Testimony
  • March 9, 2017

Comment Letters on Market Stabilization Proposed Rule

CHA joined with national organizations representing child health advocacy organizations and the essential community providers (ECPs) to submit two joint comment letters to CMS on the agency's Market Stabilization proposed rule, Patient Protection and Affordable Care Act; Market Stabilization.

The children's groups' letter urges CMS to maintain and improve current standards for provider networks, essential community provider (ECP) contracting, enrollment processes, and coverage provisions, rather than adopting the changes in the proposed rule.

Specifically, the letter urges CMS to:

  • Retain the current -2/+2 de minimus actuarial value range to protect families of children with serious, complex or chronic conditions from higher out-of-pocket expenses associated with lower AV plans.
  • Maintain a federal role in network adequacy that, at a minimum, establishes a framework for state regulations in order to curb the trend toward limited provider networks that do not include the trained and experienced pediatric specialty providers that children need.
  • Maintain the current requirement that plans contract with a minimum of 30 percent of available essential community providers to ensure that vulnerable, low-income and underserved children have access to these uniquely qualified providers.
  • Allow parents who have a new baby or adopt a child to change to a different QHP and metal tier of coverage during the special enrollment period to assure that their plan has the level of coverage (e.g., benefits, cost-sharing requirements) and provider network that meets the child’s needs.

The ECP letter urges CMS to maintain the current requirement that qualified health plans offer a contract to at least 30 percent of available ECPs in the plan's service area. The proposed rule reduces the minimum threshold to 20 percent.

For more detail, CHA's summary of the proposed rule highlights those provisions with implications for children's health care access.