posted by AHIP
on January 15, 2021
On behalf of America’s Health Insurance Plans (AHIP), thank you for the opportunity to offer comments in response to the Department of Health and Human Services (HHS) Notice of Benefit and Payment Parameters for 2022 and Pharmacy Benefit Manager Standards (“Payment Notice”) and Updates to State Innovation Waiver (Section 1332) Implementing Regulations, published in the Federal Register on December 4, 2020 (CMS-9914-P).
We appreciate the Administration’s commitment to regulatory stability, streamlined regulations, and improved exchange operations. This ongoing partnership is critical to ensure affordable coverage options, competition, and programmatic stability.
With these goals in mind, AHIP’s recommendations focus on two themes: (1) promoting stability and predictability for plan year 2022 by ensuring critical information is finalized in a timely manner; and (2) ensuring proposals for significant changes are carefully developed and thoughtfully evaluated with stakeholder input. We recommend HHS not finalize major changes, such as adopting the proposed Exchange direct enrollment (DE) model or significant changes to the risk adjustment model at this time to allow additional time for stakeholder input. Read our comment letter here.