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Families USA’s Public Comments on the Proposed Program Integrity Rule


On November 7, 2018—the morning after Election Day—the Trump administration proposed an “Exchange Program Integrity” rule governing coverage provided in health insurance marketplaces. Some parts of the proposal appear useful. Some changes offer potential help to consumers but require changes. Others threaten to create serious harm. On January 8, 2019, Families USA filed comments about each portion of the proposed rule. Perhaps the most noteworthy provision requires all exchange plans that chose to cover abortion services to send two separate bills, every month, to each member: a $1 monthly bill for coverage of abortion services; and a second bill for all other coverage. A consumer who does not pay both charges loses their insurance, so one foreseeable result of the proposal is significant losses in coverage. Moreover, rather than cope with this bureaucratic nightmare, insurers are likely to stop offering abortion coverage. But simply, this rule is a sneak attack on women’s access to reproductive health care, using paperwork requirements to undermine women’s ability to use their own money to purchase private coverage of necessary abortion services.

Download the comments here.