Comments on the Improving Health Insurance Markets for 2022 and Beyond Proposed Rule

In this comment letter, we respond to the Biden administration’s proposed rule governing important aspects of the health insurance Marketplaces. First, we provide feedback on the proposed payment parameters, largely supporting the Administration’s proposed changes. Second, we comment on proposed modifications to 1332 waivers, sharing our deep concern that the Administration is proposing to maintain outdated statutory understandings that will close off progressive policy ideas for state Marketplaces. Finally, we lay out several critical areas for future CCIIO rulemaking.