Comments on HHS Notice of Benefit and Payment Parameters for 2022, Pharmacy Benefit Manager Standards, and State Innovation Waiver Regulations
By Frederick Isasi, Stan Dorn, Cheryl Fish-Parcham,
Families USA commented on a set of proposed regulations issued late in the Trump administration regarding a large set of marketplace issues. We objected to a proposed shift to private entities for enrollment, undermining of the marketplace, delays in language access, 1332 regulations, and a formula that decreases premium assistance. We supported expansion of special enrollment periods, and supported some changes in risk adjustment while opposing others.