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Comment
February 2019

Families USA Comment on the Notice of Benefit and Payment Parameters for 2020

On January 17, the Centers for Medicare and Medicaid Services (CMS) published a proposed rule that would raise consumers’ out-of-pocket costs for health care under individual and employer-sponsored health insurance plans, and decrease premium assistance in the individual marketplace. The rule also proposes a number of other changes: to navigator programs, to web broker and direct enrollment entity standards, to drug formularies and cost-sharing requirements, to the benefits that plans must cover, and to abortion coverage. Importantly, the preamble to the rule also asks for comment on whether two policies that are important to consumers should continue: automatic re-enrollment in health plans; and “silver-loading” – that is, letting issuers add the cost of providing cost-sharing reductions to silver plans on the marketplace, where CMS will reimburse these costs through premium credits.

Families USA’s February 19 comments on the proposed rule include the following:

  • Stress the importance of CMS continuing automatic re-enrollment in health plans; and “silver-loading.”
  • Urge withdrawal of a flawed new method for adjusting premium credits and cost sharing that would harmfully increase costs for low and middle income consumers;
  • Urge that navigators be funded and trained to continue to assist with post-enrollment issues as well as initial enrollment;
  • Urge stronger standards for web brokers and direct enrollment entities, including that web brokers be required to provide comprehensive information to consumers about all marketplace plans available to them; and
  • Urge CMS to withdraw a proposal that could limit access to abortion services by imposing burdensome requirements on insurers that provide that coverage;
  • Support allowing plans to include newly available generic medications on their formularies, thereby decreasing drug costs, but oppose other policies that are proposed with the intention of lowering drug costs but would have the effect of harming consumers’ access to affordable medicines;
  • Support changes to risk-adjustment methodology (compensating insurers who serve expensive enrollees), and ask CMS to also consider  the costs of part-year enrollees in risk adjustment formulas.